Addressing Medicare Hospital Readmissions

Congressional research reportMay 25, 2012

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Addressing Medicare Hospital Readmissions

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May 25, 2012

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R42546

CRS Report for Congress

Prepared for Members and Committees of Congress

Addressing Medicare Hospital Readmissions

Summary

Nearly 20% of Medicare beneficiaries aged 65 and over who were admitted to a hospital in 2005

were readmitted within 30 days following their initial discharge. The Medicare Payment Advisory

Commission (MedPAC) estimated that these readmissions cost the Medicare program as much as

$15 billion per year and that perhaps as much as two-thirds of these readmissions may be

preventable. Many policymakers believe that different care transition programs coupled with

payment reforms can constrain hospital readmissions among Medicare’s fee-for-service (FFS)

beneficiaries, could improve patient care, and may generate cost savings for the program.

Hospital readmissions are associated with a number of factors and are not necessarily attributable

to problems with the quality of patient care, but strong evidence indicates specific interventions to

better manage care transitions at the time of hospital discharge could reduce readmissions for

certain conditions.

Medicare is building on past work by Quality Improvement Organizations (QIOs) to help

providers identify the underlying causes of hospital readmissions in their communities and then

develop different strategies to prevent those rehospitalizations. In their newest round of Medicare

contracts, which began August 1, 2011, QIOs will work to reduce readmissions 20% by 2013 and

provide technical assistance to participants in the Community Care Transitions Program (CCTP),

a $500 million, five-year demonstration program established by the Patient Protection and

Affordable Care Act (ACA as amended, P.L. 111-148) to help participating hospitals improve

discharge procedures and manage patients’ care transitions more effectively. CCTP may be

continued or expanded if the Office of the Actuary (OACT) certifies that the expansion would

reduce Medicare spending without reducing quality. By mid-March 2012, 30 sites had been

selected.

As well as establishing CCTP, ACA included several payment initiatives to encourage FFS

providers, particularly hospitals, to work to minimize rehospitalizations and coordinate patient

care across settings. Two initiatives in particular are discussed in this report, the Hospital

Readmission Reduction Program (HRRP) and bundled payments. The HRRP will penalize an

acute care hospital with higher than expected readmission rates by as much as 1% of its base

payments starting in FY2013. Initially, the HRRP must use the three existing readmission

measures that are endorsed by the National Quality Forum (NQF) and are included on Medicare’s

Hospital COMPARE website (where publically reported data can be used to assess hospital

performance). Hospitals and industry advocates have expressed concerns about the existing

measures and the effect of the readmission penalties on certain safety-net hospitals; issues that are

likely to attract significant Congressional attention as the program’s implementation date

approaches. CMS is also exploring bundled payment methods where a single payment is made for

a defined group of services rather than individual payments for each service. The national

bundled payment pilot program established by the Center for Medicaid and Medicare Innovation

(CMMI) is a three-year project starting in 2012 that will encompass four different bundled

payment models. Changing these FFS financial incentives may be Medicare’s most effective

strategy for addressing hospital readmissions.

This report examines the complex issue of hospital readmissions along with Medicare’s ongoing

efforts and future activities to reduce unnecessary readmissions.

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Addressing Medicare Hospital Readmissions

Contents

Introduction...................................................................................................................................... 1

Factors that Influence Hospital Readmissions........................................................................... 4

Medicare’s Readmission Measures ........................................................................................... 7

Medicare’s Existing Payment Incentives and Conditions of Participation (COP) for

Discharge Planning............................................................................................................... 10

Current Medicare Care Transition Initiatives ................................................................................ 13

Community-Based Care Transitions Program (CCTP) for High-Risk Medicare

Beneficiaries ......................................................................................................................... 16

Forthcoming Medicare Payment Initiatives to Address Readmissions .......................................... 25

The Hospital Readmissions Reduction Program (HRRP) ....................................................... 26

National Pilot Program of Payment Bundling ......................................................................... 28

Bundled Payment for Care Improvement Initiative................................................................. 30

Concluding Observations............................................................................................................... 34

Tables

Table 1. Causes of and Tools for Addressing Readmissions .......................................................... 14

Table 2. Key Features of Five Different Care Transition Models .................................................. 20

Table 3. Differences in Eligible Services Included in the Four Bundled Payment Models ........... 31

Table 4. Characteristics of the Four Bundled Payment Models under CMMI’s Bundled

Payment Initiative ....................................................................................................................... 33

Table B-1. Jencks Readmission Framework .................................................................................. 44

Table C-1.Illustrative Calculation of Hospital HRRP Penalty ....................................................... 53

Appendixes

Appendix A. Hospital Actions That May Mitigate Against Readmissions .................................... 36

Appendix B. Different Readmission Measures and Methodologies .............................................. 43

Appendix C. Illustrative Example of the Hospital Readmission Reduction Program

Calculation .................................................................................................................................. 52

Contacts

Author Contact Information........................................................................................................... 54

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Addressing Medicare Hospital Readmissions

Introduction

Policy-makers and patient advocates are concerned that Medicare patients are cycling in and out

of acute care hospitals too frequently and that high hospital readmission rates may be a marker of

poor quality of care.1 Nearly 20% of Medicare beneficiaries aged 65 and over who were

hospitalized in 2005 were readmitted within 30 days following their initial hospital discharge.

The Medicare Payment Advisory Commission (MedPAC) estimated that these readmissions cost

$15 billion per year in hospital payments and that as much as two-thirds of these readmissions

may be preventable.2 As Medicare hospital stays have become shorter and beneficiaries’ postacute care becomes more fragmented, the movement of inpatients out of hospitals into other

health care settings and the transition of Medicare beneficiaries between different post-acute

providers have been identified as areas that need attention. In MedPAC’s view, existing incentives

to coordinate care across providers and settings are limited, because Medicare pays each provider

separately and because payments to these providers are not affected by their ability or efforts to

coordinate care across settings. In fact, under the existing fee-for-service (FFS) payment system,

hospitals that devote resources to reducing readmissions may suffer financially (unless other

patients fill the unused beds). Changes that address hospital readmissions among Medicare’s FFS

beneficiaries, such as placing a greater emphasis on effective discharge planning, adoption of

different care management programs, and payment reforms, may improve patient care and

generate cost savings for the program.3

The implementation of these changes becomes more complicated because readmission rates,4 the

use of post-acute services,5 and hospital utilization in general,6 vary substantially among

geographic locations. Communities with higher admission rates tend to have higher readmission

rates and perhaps a greater dependence on hospitals as a site of care.7 Also, the type of post-acute

1

Bernard Friedman and Jayasree Basu, “The Rate and Cost of Hospital Readmissions for Preventable Conditions,”

Medical Care Research and Review, vol. 61, no. 2 (June 2004), pp. 225-240.

2

MedPAC, Report to Congress: Promoting Greater Efficiency in Medicare, June 2007, Chapter 5. See

http://www.medpac.gov/documents/Jun07_EntireReport.pdf. (Subsequently referred to as MedPAC, Greater

Efficiency, June 2007.)

3

Although this report focuses on readmissions, some of these same strategies are thought to address preventable initial

admissions. In fact, hospitals with high admission rates may be most likely to have high readmission rates, suggesting

that addressing the needs of those patients most likely to be admitted may also reduce overall readmission rates. Arnold

M. Epstein, Ashish K.Jha, and John E Orav, “The Relationship Between Hospital Admission Rates and

Rehospitalizations.” New England Journal of Medicine (NEJM); vol. 365 (December 15, 2011), pp. 2287-2295.

(Subsequently referred to as Epstein et al., “The Relationship Between Hospital Admission Rates and

Rehospitalizations.”)

4

New Jersey (21.9%), Louisiana (21.9%), and Illinois (21.7%) had the highest while Oregon (15.7%), Utah (14.2%),

and Idaho (13.3%) had the lowest readmission rates for Medicare beneficiaries. Stephen F. Jencks, Mark V. Williams,

and Eric A. Coleman, “Rehospitalizations among Patients in the Medicare Fee-for-Service Program,” New England

Journal of Medicine, vol. 360 (April 2, 2009), pp. 1418-1428. (Subsequently referred to as Jencks, Williams, and

Coleman, “FFS Medicare Rehospitalizations.” NEJM, vol. 360 pp. 1418-1428) Also see Epstein et al., “The

Relationship Between Hospital Admission Rates and Rehospitalizations.”

5

MedPAC, Report to Congress: Regional Variation in Medicare Service Use, January, 2011. See

http://www.medpac.gov/documents/Jan11_RegionalVariation_report.pdf.

6

David Goodman, Elliot Fisher, and Chiang-Hua Chang, After Hospitalization: A Dartmouth Atlas Report on PostAcute Care for Medicare Beneficiaries, September 28, 2011. Available at http://www.dartmouthatlas.org/data/topic/

topic.aspx?cat=30.

7

Factors such as differences in patient status, the quality of inpatient care, and the availability of ambulatory services in

the community may also contribute to differences in readmission rates across certain regions and hospitals. Ibid., p. 6.

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care (if any) a beneficiary receives after the initial discharge can vary and may affect readmission

rates. After a hospital stay, roughly 40% of Medicare beneficiaries are discharged to a post-acute

setting providing skilled nursing care or rehabilitation services. Rates of 30-day hospital

readmissions among beneficiaries discharged to skilled nursing facilities (SNFs) have been

increasing over time; almost one-quarter of the Medicare beneficiaries discharged from a hospital

to a SNF in 2006 were readmitted to the hospital within 30 days.8 MedPAC has found that the

risk-adjusted rate at which Medicare covered SNF patients with any of five potentially avoidable

conditions (congestive heart failure, respiratory infection, urinary tract infection, sepsis and

electrolyte imbalance) were rehospitalized in 2009 was 14.2%, with considerable variation among

SNFs.9 Under current Medicare FFS payment rules, hospitals and post-acute providers lack

financial incentives to address hospital readmissions by coordinating beneficiaries’ care,

improving clinical information sharing, ensuring appropriate placement across the range of

different post-acute settings, or addressing other inefficiencies across providers.10

Hospitals must comply with standards established by Medicare’s Conditions of Participation

(COP) to bill the program. Medicare’s COP requires hospitals to have a discharge planning

process that applies to all patients. Under existing regulations, hospitals are expected to evaluate

whether a patient is expected to experience adverse health consequences upon discharge, develop

a discharge plan and arrange for its initial implementation, and counsel the patient, family

members or interested parties about the availability of post-hospital care. However, hospital

discharge planning is viewed as limited in scope and influence on patient behavior. (Other factors

associated with rehospitalizations and the effectiveness of hospital discharge planning are

discussed in Appendix A.) Transitional care models are intended to supplement the existing

hospital discharge planning process, provide patients with services both prior to discharge and

after discharge from the hospital, and often emphasize targeting care for “vulnerable” chronically

ill patients (those who are older, in poor health, or who have been hospitalized previously) most

at risk for hospital readmission.11

Generally, a readmission is seen as an outcome that is preceded by a number of intermediary

events that, in certain circumstances, may be addressed and remedied. From August, 2008

through July, 2011, as part of their 9th Statement of Work (SOW) Medicare’s Quality

Improvement Organizations (QIOs) in 14 states have been assessing primary factors affecting

readmissions to develop interventions to target these factors. In their view, the causes of

readmission include

8

The policy factors affecting these rehospitalizations may depend upon whether the beneficiary was originally

admitted from his or her home or a nursing home. Vincent Mor, Orna Intrator, Zhanlian Feng,and David C. Grabowski,

“The Revolving Door of Rehospitalizations from Skilled Nursing Facilities,” Health Affairs, vol, 29, no 1, January

2010, pp. 57-64.

9

Rehospitalization rates vary by type of SNF and ownership as well as the percent of dual-eligible beneficiaries treated

in the facilities. MedPAC, Report to Congress: Medicare Payment Policy March 2012, Chapter 7. pp. 194-200.

http://www.medpac.gov/chapters/Mar12_Ch07.pdf.

10

As an added complication, each post-acute provider, including SNFs, inpatient rehabilitation facilities (IRFs), longterm care hospitals (LTCHs) and home health agencies (HHAs) has a different Medicare prospective payment system,

patient assessment instrument (if any), and Medicare coverage requirement.

11

Transitional care complements but has different features than other care management models, such as care

coordination, disease management and case management. Mary D. Naylor, Linda Aiken, Ellen Kurtzman, Danielle

Olds, and Karen Hirshman, “THE CARE SPAN: The Importance of Transitional Care In Achieving Health Reform,”

Health Affairs, vol 30, no. 4 (April 2011) pp. 746-754. (Subsequently referred to as Naylor et al., “The Importance of

Transitional Care”).

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•

Fragmented documentation of medical conditions or failure to communicate need

for medical treatment;

•

Poor patient self-management;

•

Inadequate follow-up in the post-discharge setting;12

•

Community infrastructure and awareness problems;

•

Insufficient patient support, including support from family caregivers; and

•

Medication discrepancies that occur during an initial admission or following a

discharge and which may result in illness or harm to a patient.

QIO’s work-to-date suggests readmissions can be reduced by bringing together community

stakeholders to create standardized processes to support patients before and after discharge from

the hospital. Other QIO readmission efforts have focused on improvements to patient and

caregiver education, medication management, or use of common patient health records to

improve communication of patient health information between providers within and outside the

hospital setting. As discussed later in “Current Medicare Care Transition Initiatives,” QIOs efforts

to address readmissions are continuing in their 10th SOW.13 QIOs are also providing technical

assistance to candidates seeking to participate in the Community Care Transitions Program

established by the Patient Protection and Affordable Care Act (ACA as amended, P.L. 111-148).

This report is intended to help Congress understand the complex issue of hospital readmissions

and Medicare’s ongoing and future activities to address those rehospitalizations.14 To that end, the

next sections of the report will discuss factors that may influence hospital readmissions,

Medicare’s readmission measures, existing payment incentives for FFS reimbursement and the

existing hospital COPs. The report will then discuss Medicare’s efforts to provide technical and

financial assistance to hospitals’ efforts to improve discharge procedures and manage patients’

care transitions. The final section of the report will discuss Medicare’s upcoming payment

initiatives to address hospital readmissions, specifically the Hospital Readmission Reduction

12

One study reports that (1) the cost of copayments for medications and follow-up visits, (2) lack of home health

coverage if the beneficiary does not meet Medicare’s current home-bound requirements, and, (3) lack of payment for

transitional care services (post-discharge phone calls, coaching services, and clinical services) are factors that providers

see as barriers to their efforts to reduce rehospitalizations. Amy Boutwell, Marian Johnson, Patricia Rutherford et al.,

“An Early Look at A Four-State Initiative to Reduce Avoidable Hospital Readmissions,” Health Affairs, vol 30, no. 7

(July 2011) pp. 1272-1280.

13

Certain changes to the QIO program were included as part of the Trade Adjustment Assistance Extension Act of

2011 (P.L. 112-40) that was enacted on October 21, 2011. These changes apply to QIO contracts entered into or

renewed starting January 1, 2012. The QIO’s 10th SOW which established projects to address hospital readmissions is

not affected.

14

Although outside of the scope of this discussion, other initiatives within the Department of Health and Human

Services (HHS) also seek to reduce hospital readmissions and warrant mentioning, in passing. For instance, the

Partnership for Patients: Better Care, Lower Costs is a public-private partnership that as one of its goals seeks to reduce

hospital readmissions by 20% over a three-year period. Other information technology (IT) initiatives within HHS seek

to improve care transitions for discharged patients, particularly the first two projects announced under the Investing in

Innovation (i2) Initiative within the Office of the National Coordinator for Health Information Technology (ONC). The

first project sought (and found three) developers to create a web-based application of the CMS discharge checklist to

help patients and their caregivers leave the hospital. At the end of January, 2012, ONC announced a second IT project,

the discharge follow-up challenge to assist with scheduling of post-hospital appointments and testing. Although not

specifically targeted to Medicare beneficiaries, these efforts, if successful, are likely to impact Medicare’s readmissions

as well.

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Program (HRRP) and the bundled payment demonstrations currently proposed by the Center for

Medicare and Medicaid Innovation (CMMI).15

Factors that Influence Hospital Readmissions

There is an ongoing debate in the academic literature and among industry advocates about which

factors influence hospital readmissions, and whether and how much control hospitals have over

these underlying factors. The challenge facing Medicare in attempting to reduce hospital

readmissions is to provide appropriate incentives, including targeted technical assistance, to

encourage hospitals to address the underlying causes and then work to minimize

rehospitalizations, particularly since readmissions generate additional Medicare payments for

hospitals. Medicare’s efforts are further complicated by a large body of research which identifies

possible causes that are associated with readmissions, with limited consensus about which should

be included for a fair assessment of hospital performance. The following discussion examines

some of the research on these factors, including a description of the mixed evidence of their

importance.

Generally, research has found that Medicare beneficiaries with certain medical conditions and

demographic characteristics are more likely than others to be readmitted to the hospital after a

discharge. Medicare FFS claims data from 2003 to 2004 indicate that readmission rates range

broadly by condition and procedure. More than three-quarters of all rehospitalizations occurred

after initial admissions for medical conditions, not surgical conditions. Most rehospitalizations

(regardless of whether the initial admission was for a surgical or a medical condition) were for

medical conditions.16 Relatively high readmission rates are found for Medicare beneficiaries with

multiple chronic illnesses.17,18 ,19 An additional factor that may be associated with readmissions is

a patient’s history of prior rehospitalizations.20 Patients with worse health—as indicated by higher

clinical severity scores—have higher 30-day readmission rates than patients with lower severity

scores. The differences in these readmission rates between the two groups have increased over

time.21

15

Medicare shared savings programs, including Accountable Care Organizations (ACOs) and other demonstration

programs concerned with case management or medical monitoring programs for chronically ill beneficiaries, are

outside the scope of this discussion.

16

84.4% of the rehospitalizations after an initial admission for a medical condition and 72.2% of the rehospitalizations

after an initial admission for a surgical condition were for a medical diagnosis. Jencks, Williams, and Coleman, “Feefor-Service Medicare Rehospitalizations,” NEJM, vol 360. pp. 1418-1428.

17

In a meta-analysis of 44 studies, the mean readmission rate was 34% for patients with chronic illnesses compared to

a mean, overall rate of 27%. Karen L. Soeken, Patricia A. Prescott, and Dorothy G. Herron et al., “Predictors of

Hospital Readmission: A Meta-Analysis,” Evaluation and the Health Professions, vol. 14, no. 3 (1991), pp. 262-281.

18

Among those 65 years and older, patients with five or more medically comorbid conditions had odds that were more

than 2.5 times the odds of patients without those conditions to have an unplanned readmission within 30 days. Edward.

R. Marcantonio, Sylvia McKean, Michael Goldfinger, Sharon Kleefield, Mark Yurkofsky, Troyen A. Brennan,

“Factors Associated with Unplanned Hospital Readmission Among Patients 65 years of Age and Older in a Medicare

Managed Care Plan,” The American Journal of Medicine, vol. 107, no. 1 (July 1999), pp. 13-17.

19

2005 data indicate that 30-day readmission rates for patients with end-stage renal disease are nearly twice as high as

readmission rates for patients without end-stage renal disease. MedPAC, Greater Efficiency, June 2007, p. 107.

20

Jencks, Williams, and Coleman, “FFS Medicare Rehospitalizations.” NEJM, vol. 360 pp. 1418-1428. Presentation by

Stephen F. Jencks, at the National Hospital Payment Reform Summit, Washington, DC, September 17, 2009.

21

This trend was demonstrated using Medicare data for FFS beneficiaries discharged from acute care hospitals from

1997, 2002, and 2007. These differences may be attributable to patients with high clinical severity scores having

(continued...)

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Demographic characteristics, such as race, age, gender, and socio-economic status have been

studied as factors influencing the likelihood of readmissions, with mixed results.22 The different

studies of readmission risk factors varied by the target condition(s) included, analytic approach,

follow-up period, and handling of deaths and hospital transfers among other features.23 Generally,

across a number of studies assessing the significance of various risk factors for hospital

readmission, there is no evidence that demographic characteristics like age, gender, or factors

such as income or education consistently predict hospital readmissions.24 There is some evidence

indicating variation in readmission rates by race and socio-economic status, cited by advocates

who wish to have those factors reflected in the readmission models.25,26,27 One study examined the

readmission rates of black and elderly Medicare patients receiving care at minority-serving

hospitals (defined as inclusion in the top 10% of hospitals by proportion of black patients served)

and non-minority serving hospitals from 2006 to 2008. It found that older black Medicare patients

had higher readmission rates than white patients for three common medical conditions: acute

myocardial infarction (AMI), congestive heart failure (CHF)28, and pneumonia (PN), but

concluded that the association of readmission rates with the site of care was consistently greater

than the association with race.29

Some have cautioned that the inclusion of certain non-clinical factors, such as race and socioeconomic status, should be avoided in statistical models used for the public reporting of health

outcomes, because these factors may be related to patient quality of care that are important to

capture and for hospitals to address.30 One concern is that including an adjustment for race or

(...continued)

increased, unobserved clinical severity or not receiving high-quality transitional care services. Matthew Press, Amol

Navathe, Jingsan Zhu, Wei Chen, Jessica Mittler, Dennis Scanlon, and Kevin Volpp, “Clinical Severity in the

Measurement of Readmission Rates: A Comparison of Medicare Beneficiaries in 1997 and 2007.” Paper presented at

the 2011 Academy Health Annual Research Meeting, Seattle, WA.

22

Devan Kansagara, Honora Englander, and Amanda Salanitro et al., “Risk Prediction Models for Hospital

Readmission: A Systematic Review,” JAMA, vol. 306, no. 15 (October 19, 2011), pp. 1688-1698.

23

Joshua West, Larry Gamm, and Brock Oxford et al., “Determinants of Preventable Readmissions in the United

States: A Systematic Review,” Implementation Science, vol. 5, no. 88 (2010), pp. 1-28.

24

Joseph S. Ross, Gregory K. Mulvey, and Brett Stauffer et al., “Statistical Models and Patient Predictors of

Readmission for Heart Failure,” Archives of Internal Medicine, vol. 168, no. 13 (July 14, 2008), pp. 1371-1386.

25

Karen E. Joynt and Ashish K. Jha, “Who Has Higher Readmission Rates for Heart Failure and Why: Implications for

Efforts to Improve Care Using Financial Incentives,” Circulation: Cardiovascular Quality and Outcomes. Journal of

the American Heart Association, vol. 4 (June 2011), pp. 53-59.

26

For instance, the odds of a readmission increases with age (per 10 years), as well as for females and African

Americans (marginal increase in odds for this group), following coronary artery bypass graft surgery. Edward L.

Hanna, Michael J. Racz, and Gary Walford et al., “Predictors of Readmission for Complications of Coronary Artery

Bypass Graft Surgery,” JAMA, vol. 290, no. 6 (August 13, 2003), pp. 773-780.

27

Trendwatch: Examining the Drivers of Readmissions and Reducing Unnecessary Readmissions for Better Patient

Care, American Hospital Association, September 2011.

28

This report will not use congestive heart failure (CHF) or heart failure (HF) interchangeably. In this instance, the

study examined rates of CHF by race and site of care.

29

Patients discharged from minority-serving hospitals had odds of readmission that were 1.23 times the odds of

readmission for patients discharged from non-minority-serving hospitals. Black Medicare patients had odds of

readmission that were 1.13 times the odds of readmission for white Medicare patients. These results varied by

condition studied. Karen E. Joynt, E. John Orav, and Ashish K Jha, “Thirty-day Readmission Rates for Medicare

Beneficiaries by Race and Site of Care,” JAMA, vol. 305, no. 7, (February 16, 2011) pp. 675-681.

30

See Harlan Krumholz et al., “Standards for Statistical Models Used for Public Reporting of Health Outcomes, AHA

Scientific Statement, Circulation: Cardiovascular Quality and Outcomes. Journal of the American Heart Association,:

2006: 113, pp. 456-462 for additional discussion with respect to preferred attributes of models used for publically

(continued...)

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socioeconomic status lowers the performance bar for hospitals that serve a high proportion of

these patients and does not provide comparable incentives to work to minimize readmissions as

other hospitals. Alternatively, hospital advocates maintain that, without such an adjustment,

safety-net hospitals serving these patient populations will be disproportionately affected and the

resulting financial penalties (when the hospitals may already be financially strained) could reduce

quality of care provided to such patient populations. Also, in their view, without such a risk

adjustment, other hospitals may have an incentive to avoid treating minority and low-income

patients if those populations are seen as having higher readmission rates. Simply stated, it can be

difficult to assess whether the high readmission rates associated with certain categories of patients

should be attributed to them or the hospitals that they predominantly use.

As an additional complication, patients may not properly manage their own health conditions or

use of medications and thus may be at risk for readmissions. The post-discharge period is a

“vulnerable phase” for patients who may have worsening clinical conditions; without appropriate

support from family members or caregivers, patients discharged from the hospital may not follow

through with nutrition and diet, medication usage, and other therapies.31 A patient who is

discharged from the hospital but does not see a primary care provider outside the hospital, may be

susceptible to readmission if the patient’s condition deteriorates and there is no adequate followup care.32 These situations may be mitigated if the physician who treated the patient in the

hospital communicates with the patient’s primary care physician or other family members, but

this does not occur routinely.33 Moreover, families of patients may not know what post-acute care

options are available to them.34 Alternatively, available, accessible options for post-acute or

follow-up care may be limited within certain communities.

Certain hospital processes and procedures could be implicated in readmissions. For instance, a

hospital that does not properly assess the medications a patient was taking prior to admission may

unknowingly prescribe a medication which has an interaction with one of the patient’s existing

medications; this could lead to an adverse event and result in a readmission. In other instances

when diagnostic information or the treatment course provided to the patient during the

hospitalization is not recorded, the patient’s primary care provider outside the hospital may not be

able to correctly diagnose or assist with the patient’s condition.35 Additionally, communication by

hospital staff and physicians to patients within the hospital is important—better patient

(...continued)

reported outcome data. (Subsequently referred to as Krumholz et al., Standards for Statistical Models, AHA Scientific

Statement Circulation: 2006).

31

Mihai.Gheorghiade, and Eric D. Peterson, “Improving Postdischarge Outcomes in Patients Hospitalized for Acute

Heart Failure Syndromes,” JAMA, vol. 305, no. 23, (2011), pp. 2456-2457. (Subsequently referred to as Gheorghiade et

al., “Improving Post Discharge Outcomes” JAMA vol. 305, no. 23, (2011), pp. 2456-2457).

32

There was no bill for a visit to a physician’s office between the patient’s discharge and rehospitalization for more

than half of the beneficiaries who were rehospitalized within 30 days after a medical discharge to the community.

Jencks, Williams, and Coleman, “FFS Medicare Rehospitalizations.” NEJM, vol. 360 p. 1426.

33

Gheorghiade et al., “Improving Post Discharge Outcomes’ JAMA vol. 305, no. 23, (2011), pp. 2456-2457.

34

Robert L. Kane, “Finding The Right Level of Posthospital Care: ‘We Didn’t Realize There Was Any Other Option

for Him,” JAMA, vol 305, no. 3, (2010), pp. 284-293. This study also provides mixed evidence for whether certain

post-discharge care settings (i.e., skilled nursing facilities or inpatient rehabilitation facilities) were better for specified

patients (e.g., with strokes or hip fractures).

35

Arnold M. Epstein, Ashish K Jha, and E. John Orav, (2011). “Explaining Variations in Readmission Rates: The

Propensity to use Hospital Services.” Paper presented at the 2011 AcademyHealth Annual Research Meeting, Seattle,

WA.

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satisfaction scores at hospitals (including patient satisfaction with discharge planning, for heart

failure and pneumonia, but not for AMI) are associated with lower risk-adjusted 30-day

readmission rates.36

Finally, hospitals currently do not have financial incentives to avoid rehospitalizations or to delay

discharges.37 Under the current FFS system, Medicare does not reimburse for supportive services

for patients (including those with complex medical conditions) even if such activities may reduce

readmissions. Medicare also does not pay hospitals or other providers for transitional care

services, another activity thought to reduce readmissions. For example, hospitals and other

providers may not provide telephone reminders about follow-up medical appointments,

medication reminders, in-home check-ups, or care coordination with outpatient providers on

behalf of the patient post-discharge because these extra services are not rewarded and result in

extra costs for hospitals or other providers.38 Additionally, shorter lengths of stay under

Medicare’s FFS payment system have been posited as an explanation for higher readmission

rates; however, compared to higher-cost hospitals, lower-cost hospitals (which are likely to

discharge patients earlier) do not have significantly higher 30-day readmission rates.39

Although certain studies indicate that readmission rates are associated with age, patient illness,

and other factors, the specific reasons such persons are readmitted may warrant continued

investigation. A variety of adverse events might occur before a hospital admission, during a

hospital stay, as a patient is being discharged, or after a patient is home or in another setting that

could result in rehospitalization. The reasons for readmission likely vary by person, by hospital,

and by care setting, if not by locality.

Medicare’s Readmission Measures

The Centers for Medicare & Medicaid Services (CMS) has drawn increased attention to the topic

of hospital readmissions by establishing readmission measures for three common Medicare

hospitalizations as quality indicators and including that data on its Hospital COMPARE website

to permit public assessment of hospitals’ performance in this area. The readmission measure for

patients treated for heart failure (HF) was finalized in the FY2009 inpatient prospective payment

system (IPPS) rule published in the Federal Register on August 19, 2008;40 the two other

measures for readmitted patients treated initially for AMI and PN were finalized in the CY2009

hospital outpatient final rule published November 18, 2008, after endorsement of the measures by

36

William Boulding, Seth Glickman, Matthew Manary, Kevin Schulman, and Richard Staelin, “Relationship Between

Patient Satisfaction With Inpatient Care and Hospital Readmission Within 30 Days,” The American Journal of

Managed Care, vol. 17, (January 2011) no. 1, pp. 41-48.

37

Vincent Mor and Richard W. Besdine,“Policy Options to Improve Discharge Planning and Reduce

Rehospitalization,” JAMA, vol. 305, no. 3, (January 19, 2011), pp. 302-303.

38

Important information in this discussion is taken from the Care Transitions Quality Improvement Organization

Support Center (QIOSC). This information may be accessed at http://www.cfmc.org/integratingcare/toolkit.htm.

39

Lena M. Chen, Ashish K Jha, Stuart Guterman, Abigail B. Ridgway, E. John Orav, and Arnold M. Epstein, “Hospital

Cost of Care, Quality of Care, and Readmission Rates: Penny Wise and Pound Foolish?” Archives of Internal

Medicine, vol 170, no. 4, (February 22, 2010), pp. 340-346.

40

This report will not use heart failure (HF) or congestive heart failure (CHF) interchangeably. CMS publishes the list

of International Classification of Disease Code (ICD) 9 codes that are used to identify heart failure cases (see pp.

27962-27963 of the May 11, 2012, Federal Register notice.) Other studies may not provide such information. This

report will use HF or CHF as indicated by study or context being discussed.

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Addressing Medicare Hospital Readmissions

the National Qualify + (NQF).41 Starting June, 2009, Hospital COMPARE indicates whether a

hospital’s risk-adjusted relative 30-day hospital readmission rates for Medicare patients initially

admitted for HF, AMI, and PN were higher, lower, or no different than the U.S. national

average.42 Beginning in FY2010, CMS’s Inpatient Quality Reporting (IQR) program also

included the readmission data used to construct risk-adjusted 30-day readmission rates for these

Medicare patients as quality measures.43 Accordingly, since then, the amount that a hospital’s

inpatient payment rate is increased each year could depend upon reporting the required quality

data on readmission measures.44

As discussed in Appendix B, the three readmission models estimate hospital-specific, riskstandardized, all-cause 30-day readmission rates for patients discharged alive to a non-acute care

setting with a principal diagnosis of HF, AMI, and PN. The measures include admissions to all

short-stay acute-care hospitals for people age 65 years and older who are in FFS Medicare and

who have a complete-claims history for 12 months prior to admission. The measures are riskadjusted to account for Medicare patients’ age, gender, past medical history, and other diseases,

conditions or comorbidities that increase readmission risks.45 The three condition-specific

readmission measures are adjusted for patient-level risk factors and account for a hospital quality

of care effect using hierarchical regression modeling techniques.46 The FY2012 IPPS final rule

indicates that CMS has adopted the same three measures for comparing hospital’s readmission

rates under the HRRP established by Section 3025 of ACA.47 Under this program, hospitals with

41

The HF measure was the first readmission measure endorsed by NQF after publication of the proposed FY2009 IPPS

rule and before publication of the final FY2009 IPPS rule. As anticipated by CMS, NQF endorsement of the other two

readmission measures occurred after publication of final FY2009 IPPS rule and before publication of the CY2009

hospital outpatient prospective payment system (OPPS) rule.

42

Currently, the public is able to assess the 30-day risk-adjusted readmission rates for a hospital for three conditions as

well as whether these rates are the same as, above or below the national average. These measures are calculated using

three years of Medicare data; for FY2012, Medicare claims and enrollment data from July 2006 to June 2009 will be

used. Hospital COMPARE’s outcome of care measures, including condition-specific readmission rates, can be found

here: http://data.medicare.gov/dataset/Hospital-Outcome-Of-Care-Measures/f24z-mvb9.

43

The Reporting Hospital Quality Data for Annual Payment Update (RHQDAPU) initiative was developed as a result

of MMA. In 2010, the RHQDAPU program was renamed the Hospital Inpatient Quality Reporting (IQR) Program. See

http://www.qualitynet.org/dcs/ContentServer?cid=1138115987129&pagename=QnetPublic%2FPage%2FQnetTier2&

c=Page.

44

See http://www.hospitalcompare.hhs.gov/staticpages/for-consumers/ooc/death-mortality-measures.aspx for

readmissions data reported in Hospital COMPARE.

45

Information on the beneficiary’s past medical history and comorbidities are based on diagnoses (ICD-9 codes) on the

patient’s discharge claim, and are from the hospital inpatient, hospital outpatient, and physician Medicare claims

submitted up to 12 months prior to the admission. See http://www.hospitalcompare.hhs.gov/staticpages/forprofessionals/ooc/risk-adjustments-and-covariates.aspx.

46

The hierarchical generalized linear model accounts for the clustering of patients within hospitals based on the

assumption that an individual hospital will provide similar quality of care across patients within its patient population,

which can be measured using hospital-specific intercepts. The hospital-specific intercepts are given a distribution in

order to account for the clustering or non-independence of patients within the same hospital. If there were no

differences amoung hospitals, then, after adjusting for patient risk, the hospital intercepts should be identical across all

hospitals. The expected number of readmissions in each hospital is estimated using its patient mix and the average

hospital-specific intercept (the average of each of the estimated hospital-specific intercepts). The predicted number of

readmissions in each hospital is estimated given the same patient mix but the hospital-specific intercept. The excess

readmission ratio for a hospital is its predicted number divided by its expected number of readmissions. This is a form

of indirect standardization that accounts for variation across hospitals in how sick their patients are when admitted to

the hospital and the variation in the number of patients a hospital treats to reveal differences in hospital-specific quality.

47

Federal Register, August 18, 2011, vol. 76, no 160, pp. 51660-51676. Until FY2015, the hospital readmission

program is required to use three readmission measures that were endorsed by NQF as of enactment. At that point,(to

the extent practicable), CMS will expand the measures to the four additional conditions identified in MedPAC’s June

(continued...)

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Addressing Medicare Hospital Readmissions

higher-than-expected spending on readmissions for Medicare FFS beneficiaries initially

hospitalized with one of these three principal diagnoses will be penalized starting in FY2013. The

penalty will be capped at 1% of a hospital’s base payments for all its Medicare discharges in

FY2013, 2% in FY2014, and 3% in FY2015 and subsequently.

CMS has established its three readmission measures as all-cause readmissions of an aged

beneficiary to the same hospital or a different hospital within 30 days of the original (index or

initial) admission, with limited exclusions of subsequent admissions.48 Academics, other policy

makers, and organizations have used different time periods and definitions to measure

readmissions.49 Also, unlike an all-cause measure, other approaches to readmission measures

attempt to identify preventable admissions and use different methods to distinguish those

readmissions that might be avoided and those that might not be avoided. As noted by certain

hospitals and their advocates, these different methods can result in different relative readmission

rates for hospitals, a comparative analyses that may have financial implications for their Medicare

payments starting in FY2013 when the penalties are implemented. Also, although Medicare’s allcause readmission measures do exclude certain readmissions, according to hospital advocates

they do not exclude a sufficient number of planned readmissions related to the original admission

or, as directed by statute, a sufficient number of unrelated readmissions.50 Finally, hospital

advocates fear that the HRRP program may end up penalizing hospitals unfairly for those factors

affecting readmissions that are out of their control. This is expressed as a particular concern for

safety-net hospitals that serve challenging patient populations within limited financial if not

clinical resources. However, as discussed subsequently, CMS has implemented other policy

initiatives and demonstration projects to provide technical and financial assistance to address

fundamental causes of rehospitalizations, particularly for certain low-performing providers.

(...continued)

2007 report. There is no requirement that NQF endorse these additional measures as long as CMS considers such

endorsed measures.

48

This methodology does not try to distinguish preventable admissions, but is an all-cause readmission measure with

the following exclusions. All admissions from Medicare disabled beneficiaries under the age of 65 are excluded. The

admissions of certain aged Medicare beneficiaries are excluded: those who die in the hospital; those who are

subsequently transferred to another acute care facility; those who are discharged against medical advice (AMA); those

without at least 30 days post-discharge enrollment in FFS Medicare; and those who are readmitted on the same day to

the same hospital with the same condition (patient admission is only counted once). Only the AMI readmission

measure will exclude patients who are discharged alive on the same day that they are admitted (because these patients

are unlikely to have had a heart attack). Also, the AMI measure will exclude readmissions within 30 days for

percutaneous transluminal coronary angioplasty (PTCA) or coronary artery bypass graft (CABG) procedures (because

these readmissions likely represent planned readmissions that are part of the same episode of care.) See

http://www.hospitalcompare.hhs.gov/staticpages/for-professionals/ooc/data-collection-methods.aspx.

49

A shorter time interval may provide a greater degree of confidence that a readmission is related to the initial

condition. A longer readmission time interval will identify more readmissions. 30-day readmission rates are the most

common readmission measure, according to Norbert .I Goldfield,, Elizabeth C. McCullough, John .S. Hughes, Anna.M.

Tang, Beth Eastman, Lisa K. Rawlins, and Richard.F Averill, “Identifying Potentially Preventable Readmissions,”

Healthcare Financing Review, vol 30, no. 1, (Fall 2008), pp. 75-91.

50

ACA directs the Secretary to use endorsed measures that have exclusions for readmissions that are unrelated to the

prior discharge (such as a planned readmission or a transfer to another acute care hospital).

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Addressing Medicare Hospital Readmissions

Medicare’s Existing Payment Incentives and Conditions of

Participation (COP) for Discharge Planning

Policy makers have longstanding concerns about the financial and quality incentives in a FFS

payment system. Generally, under FFS, a provider receives a payment, set in advance, for each

service, bears the risk for the number and costs for inputs that comprise that service, but has no

limit on the number of services provided. Most typically, payment is made regardless of quality

or outcomes.51 The current design of Medicare’s IPPS for acute care hospitals in particular (and

FFS generally) does not provide incentives to hospitals to contain avoidable readmissions for

beneficiaries or to improve the quality of care provided.52 Medicare now pays for all readmissions

except when patients are rehospitalized within 24 hours after discharge for the same condition for

which they were originally hospitalized.53 Under existing payment incentives, hospitals could lose

income by reducing readmissions, as fewer rehospitalizations would result in fewer billable

discharges. Under Medicare FFS, hospitals and physicians are usually paid separately, even if a

physician is working in the hospital. In fact, although IPPS hospitals are usually paid on a percase basis, physicians are typically paid on a per-service basis. Similarly, post-acute care

providers of post-hospital care are each paid separately and receive more reimbursement for each

Medicare admission or episode of home health care.

Under IPPS, Medicare pays for most acute-care hospital stays using a prospectively determined

payment for each discharge, intended to cover the services provided during a hospital stay;54 any

differences between Medicare payments and hospital costs, either profits or losses, are absorbed

by the hospital. In essence, hospitals are financially rewarded for the efficient delivery of medical

and surgical care and are more likely to discharge patients earlier.55 These incentives to provide

efficient care also extend to the amount of resources that hospitals dedicate to discharge planning.

Hospitals that participate in the Medicare program are required by Medicare’s COP to provide

discharge care instructions to Medicare beneficiaries.56 These requirements are subject to survey

and recertification efforts by state agencies or by CMS-approved accrediting bodies.

51

Harold D. Miller, “From Volume to Value: Better Ways to Pay For Health Care,” Health Affairs, vol. 28, no. 5

(September/October 2009), pp. 1418-1428.

52

Sheila Leatherman, Donald Berwick, and Debra Iles, Lawrence S. Lewin, Frank Davidoff, Thomas Nolan, and

Maureen Bisognano, “The Business Case For Quality: Case Studies and An Analysis,” Health Affairs, vol. 22, no. 2

(March/April 2003), pp. 17-30.

53

When a patient is discharged or transferred from an IPPS hospital and is readmitted to the same hospital on the same

day for symptoms related to, or for the evaluation and management of, the prior stay’s medical condition, the two

hospital stays are combined. Also, QIOs and other Medicare contractors have the authority to review readmissions for

medical necessity and related conditions. CMS Medicare Claims Processing Manual, Chapter 3, Section 40.2.5.

54

Payments under IPPS depend on the relative resource use associated with a patient classification group, referred to as

the Medicare severity (MS) diagnosis related groups (DRG or collectively, MS-DRG), to which the patient is assigned

based on an estimate of the relative resources needed to care for a patient with a specific diagnosis and set of care

needs. Medicare’s IPPS includes adjustments that reflect certain characteristics of the hospital. For instance, a hospital

with an approved resident training program could qualify for an indirect medical education (IME) adjustment; hospitals

that serve a sufficient number of poor Medicare or Medicaid patients would receive higher Medicare payments because

of their disproportionate share hospital (DSH) adjustment. Through FY2012, hospitals located more than 15 miles from

another hospital with less than 1,600 total discharges receive a low-volume adjustment. Hospitals in Maryland are not

paid using IPPS; rather, they receive Medicare payments based on a state-specific Medicare reimbursement system.

55

MedPAC, Greater Efficiency, June 2007 pp. 105-106.

56

42 CFR 482 contains the COP for hospitals, which are the minimum health and safety standards that hospitals must

meet to be Medicare and Medicaid certified. These include, among numerous requirements, requirements related to

patients’ rights, emergency services, outpatient services, medical record services, and laboratory services. See

(continued...)

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Addressing Medicare Hospital Readmissions

The Medicare discharge-planning COP regulation (42 CFR 482.43) requires Medicare

participating hospitals (more than 90% of all acute-care hospitals in the United States) to have a

discharge planning process that applies to all patients. The hospital is required to identify all

patients who are expected to experience adverse health consequences upon discharge at an early

stage of hospitalization. The hospital must provide a discharge-planning evaluation to these

patients and to other patients upon request; this evaluation must be done on a timely basis and

must include an evaluation of the patient’s likely need for and availability of post-acute services.

This information must be included in the patient’s medical record and the hospital must discuss

the evaluation results with the patient or patient’s representative. The hospital must develop any

necessary discharge plan and arrange for its initial implementation.57 The hospital must counsel

the patient, family members or interested parties as necessary to prepare them for post-hospital

care and advise them of its availability.58 The hospital must transfer or refer patients along with

necessary medical information to appropriate facilities, agencies, or outpatient services as needed

for follow-up or ancillary care.

Despite these requirements, some studies have found instances in which discharge planning is

incomplete and necessary information is not provided by hospitals to physicians and post-acute

providers in a timely manner. A literature review of 55 observational studies published between

1970 and 2005 indicated that primary care physicians considered the following information to be

among the most important components of discharge information: a patient’s main diagnosis;

pertinent physical findings; results of procedures and laboratory tests; and discharge medications,

with reasons for any changes to the previous medication regimen; among other information.59

However, these studies also found that audits of hospital discharge documents, which are often

physician-dictated and transcribed, demonstrated a frequent absence of such information. In

addition, only between 12% and 34% of physicians treating a patient after a hospital discharge

had a copy of the patient’s hospital discharge summary.60 Another analysis of discharge

summaries of adults 70 years and older at an academic teaching facility found that 74% of

summaries did not include pending test results and 82% of the summaries did not include

information regarding patient’s final cognitive status.61 Generally, outpatient physicians who do

not have complete and timely information about a patient’s case may not make adequate followup care decisions.

(...continued)

http://www.cms.hhs.gov/CFCsAndCOP/06_Hospitals.asp#TopOfPage.

57

Both the discharge plan evaluation and a discharge plan must be developed by, or under the supervision of, a

registered professional nurse, social worker, or other appropriately qualified personnel.

58

Among other requirements related to the discharge plan, the hospital must include, where appropriate, a list of home

health agencies or skilled nursing facilities available to the patient, that are participating in the Medicare program and

serving the area in which the patient resides or, for skilled nursing facilities, in the geographic area the patient requests.

59

After analyzing these studies, the authors found that discharge summaries lacked the following information (results

were reported as both a median and a range of percentage of occurrences): diagnostic test results, 38% (ranging from

33% to 63%); the treatment or hospital course, 14.5% (ranging from 7% to 22%); discharge medications, 21% (ranging

from 2% to 40%); test results pending at discharge, 65% (no range available); and follow-up plans, 14% (ranging from

2%-43%). Sunil Kripalani, Frank LeFevre, and Christopher. O. Phillips, Mark Williams, Preetha Basaviah, David W.

Baker, “Deficits in Communication and Information Transfer Between Hospital-based and Primary Care Physicians:

Implications for Patient Safety and Continuity of Care,” JAMA, vol. 297, no. 8 (February 28, 2007), pp. 831-841.

60

Ibid.

61

The study also found that higher discharge summary scores were associated with reduced 30-day readmissions.

Alicia Arbaje, Vishnu Surapaneni, Karen Chen, Ivana Vaughn, Kathryn Eubank, and Bruce Leff, “Higher Quality

Discharge Summaries of Hospitalized Older Adults are Associated with Reduced Risk of Readmission: Instrument

Development and Outcomes,” Paper presented at the 2011 Academy Health Annual Research Meeting, Seattle, WA.

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Addressing Medicare Hospital Readmissions

The evidence regarding the impact of hospital discharge planning activities as now conducted on

hospital readmissions may depend upon measures used to assess discharge planning. A study used

two different discharge planning measures to evaluate CHF and PN readmissions.62 It found no

association between CHF readmission rates and a measure based on whether discharge planning

was documented in the medical record chart.63 (As noted by the author, this measure may simply

capture whether hospitals document their activities, not the adequacy of the process or the

sufficiency of the information conveyed to patients, caregivers, and post-acute providers.) There

was only a modest association between PN and CHF readmissions and a readmission measure

based on the patient-reported experience with discharge planning. In fact, there was only a weak

correlation between the two discharge measures.64

As discussed in the next section, there is a body of work that supports the importance of

comprehensive and timely discharge planning as a strategy to reduce hospital readmissions. A

meta-analysis of 8 studies of HF patients receiving comprehensive discharge planning, which

generally entails post-discharge activities, had 75% the risk of hospital readmission compared to

patients with HF treated with usual care.65 A systematic review of 21 randomized controlled trials

with patients having a mix of medical and surgical conditions found that patients with an

individualized discharge plan, compared to those without an individualized discharge plan, had

85% of the readmission risk.66 In its June 2011, report, MedPAC recommended that the hospital

COP be updated to encourage the adoption of different processes that are thought to improve

patient outcomes. For instance hospitals could be required to get discharge instructions to the

appropriate community provider within 48 hours of discharge (which is thought to reduce

hospital readmission rates).67 On October 24, 2011, CMS published proposed changes to the

hospital (and critical access hospital) COP, primarily to streamline burdensome or dated

regulations. These regulations were finalized on May 16, 2012 and become effective July 16,

2012. There were no modifications to the existing hospital discharge planning requirements.

The following section will discuss recent and ongoing efforts to identify certain systemic causes

and structured approaches to address Medicare rehospitalizations within specific providers and

62

Ashish K. Jha, E. John Orav, and Arnold M. Epstein, “Public Reporting of Discharge Planning and Rates of

Readmission” NEJM, 2009; 361: 2637-45 examined two different discharge measures to evaluate CHF and PN

readmissions to conclude that efforts to publically report data on discharge planning was not likely to yield large

reductions in unnecessary admissions.

63

Performance on the chart-based discharge measure was measured using a scale from 0-100. The authors note that

performance criteria were met if the medical record stated that the patient or a caregiver was provided with written

instructions or educational material prior to discharge addressing the following: activity level, diet, discharge

medications, follow-up appointment, weight monitoring, and what to do if symptoms worsen.

64

Low correlation between performance evaluated with the two discharge planning measures may be due to the fact

that the chart-based measure had information from CHF patients only, while the patient-reported measure had

information from all hospitalized medical and surgical patients.

65

Christopher Phillips, Scott Wright, David Kern, Ramesh Singa, Sasha Sheppard, Haya Rubin, “Comprehensive

Discharge Planning With Postdischarge Support for Older Patients With Congestive Heart Failure”, JAMA, vol. 291,

no. 11 (2004), pp. 1358-67.

66

Sasha Shepperd, Jacqueline McClaran, Christopher Phillips, Natasha Lannin, Lindy Clemson, Annie McCluskey, Ian

Cameron, Sarah Barras, “Discharge Planning from Hospital to Home”, The Cochrane Library, published online

January 20, 2010. Available at http://onlinelibrary.wiley.com/doi/10.1002/14651858.CD000313.pub3/abstract.

67

MedPAC also recommended changes in the enforcement of COP and the correction of provider deficiencies through

the development of intermediate sanctions and other interventions. Issues associated with how to define, measure and

audit compliance would need to be addressed. MedPAC, “Enhancing Technical Assistance to Providers,” June 2011,

pp. 107-112.

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Addressing Medicare Hospital Readmissions

communities, including the recently implemented pilot project, the Community Based Care

Transitions Program.

Current Medicare Care Transition Initiatives

Prior to the enactment of ACA, from August 2008, through July 2011, during its 9th SOW, QIOs

in 14 states collaborated with providers in selected communities to identify the underlying causes

of hospital readmissions in their communities and then develop different strategies to prevent

those rehospitalizations.68 QIOs sought to identify causes of poor transitional care and to develop

targeted intervention strategies in order to improve patient outcomes, such as reducing 30-day

readmission rates. The Care Transitions Quality Improvement Organization Support Center

(QIOSC)—which assisted Medicare QIOs in the care transition project—found three fundamental

causes of patient readmissions: (1) declining health conditions that were not being properly

managed, (2) medication regimens that were not appropriate, and (3) inappropriate use of

emergency rooms (rather than using other types of medical services).69 The QIOSC attributed

these problems to three systemic gaps in care for patients:70

•

Lack of engagement or activation of patients and families into effective postacute self management,

•

Lack of standard and known processes among providers for transferring patients

and medical responsibility, and

•

Ineffective or unreliable sharing of relevant clinical information.

To address these gaps, QIOs worked on different approaches to (1) engage (or activate) patients;71

(2) develop standard, known discharge processes, including scheduling necessary follow-up

care;72 and (3) ensure that clinicians and providers have necessary, timely information on the

patient’s condition and need for follow-up care.73 Table 1 provides a brief summary of underlying

68

CMS has been involved with supporting care transitions since 2003, when it joined with the Administration on Aging

(AoA) to fund Aging and Disability Resource Center care transitions programs. Local area agencies on aging had been

working with Medicare QIOs in some states on the 9th SOW care transitions project.

69

A QIO support contractor (also called a national coordinating center) leads national efforts to support the local QIOs

in achieving the goals of each SOW project. The project support contractor is the contact that sends, receives and

disseminates information to the QIOs, collects and reports data, establishes and maintains contacts with national

clinical quality improvement experts, and gathers or develops quality improvement tools. The Colorado Foundation for

Medical Care (CFMC) was the QIOSC for the 9th SOW care transitions project.

70

http://www.cfmc.org/integratingcare/toolkit_rca.htm.

71

Patient activation means that patients have information about their condition, understand warning signs that indicate

a clinical deterioration in their health status; patients (or their representatives) know how to advocate for themselves in

order to ask appropriate questions. Patient activation also may include a personal health record, an emergency care

plan, a pill box or medication manager, and instruction using a “teach-back” method—where the patient explains to a

provider or “coach” (in order to ensure that he or she understands) what his or her condition is, what medications are

being taken, or other issues.

72

In the 9th SOW, QIOs developed a number of protocols, standard forms, or best practices to assess patients’ health

status, routinize discharge procedures and schedule necessary follow-up care.

73

In the 9th SOW, depending up the locality, QIOs identified care coordination efforts, which could link providers

across settings, (data sharing between providers inside and outside the hospital); discharge process improvements, such

as notifications given to a patient’s primary care physician; and community outreach, which could provide better social

supports and assistance tailored to the patient’s needs.

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Addressing Medicare Hospital Readmissions

causes of hospital readmissions, their significance for readmissions as well as specific

interventions thought to address those contributing factors. This information is supplemented by

the discussion in Appendix A of this report.

Table 1. Causes of and Tools for Addressing Readmissions

Significance for

readmissions

Specific interventions

to address problem

Improve discharge planning –

Provide clear, timely, understandable

information or instructions regarding

patients’ likely need for post-hospital

treatment, as well as post-acute

treatment options to all patients or

their representatives. Develop

standardized approaches to providing

appropriate discharge planning for

patients at risk for rehospitalization.

Future

hospitalizations

may be reduced, in

part, by informing

patients and

caregivers in a

timely manner

about how best to

manage the

patient’s care

following hospital

discharge, as well

as regarding

availability of postacute providers in

the geographic

area.

(1) Create a patient

health record. (2)

Evaluate the hospital

discharge plan. (3)

Communicate with

providers in the hospital

to discuss tests and

patient care plan.

Poor patient selfmanagement - Many

patients may not receive

information they need to

manage their care. For

instance, heart failure

patients did not receive

information about

worsening symptoms, diet,

drug interactions, followup appointments, and

weight monitoring.

Educate patients on selfmanagement of care – Teach

patients and their representatives

how to manage and advocate for

their health care needs to prevent

the unnecessary decline of patient

health and/or address the

appropriate interventions for the

patient’s health.

Patient behavior

could contribute to

risks for future

hospitalizations,

due to

inappropriate use

of medications,

poor understanding

of signs of

deteriorating

health, or other

poor management.

(1) Make follow-up

appointments and

coordinate referrals for

community resources.

(2) Discuss test and

laboratory results with

patients. (3) Assist

patients with

understanding

prescribed medications.

(4) Coach patients to

advocate for their own

health needs and to

recognize health warning

signs. (5) Follow-up with

patients after discharge,

including home visits and

telephone calls.

Lack of post-discharge

follow-up - Many patients

are not meeting with a

physician outside the

hospital setting following

hospital discharge. In

addition, a large

proportion of patients are

not receiving discharge

instructions. Around 25%

of Medicare beneficiaries

are reported to have been

rehospitalized following a

Improve post-acute follow-up

and patient support - Provide

access and reminders to patients and

their representatives to necessary

post-acute care, including

rehabilitative, home health, or skilled

nursing services. Fill in

communication gaps between

hospital and other providers by

ensuring sharing of appropriate

clinical information.

Information

regarding patient

treatment history

or post-discharge

plans may not be

available to the

post-acute

providers—

including home

health agencies,

physicians, or

SNFs—resulting in

treatment errors

(1) Make follow-up

appointments and

coordinate referrals for

community resources.

(2) Create a patient

health record. (3)

Support selfmanagement. (4) Use

bundled payment

methodology.

Problem

Goal

Fragmented

documentation Diagnostic test results,

hospital treatment

information, tests pending

at discharge, or follow-up

plans—which are

considered essential by

physicians treating

discharged patients—are

often not provided in

hospital discharge

summaries.

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Addressing Medicare Hospital Readmissions

Problem

Goal

stay in a skilled nursing

facility (SNF).

Significance for

readmissions

Specific interventions

to address problem

or poor care.

Community

infrastructure

problems - Substantial

variation among states in

regard to hospital

readmission from SNFs

has been observed.

Variation among states has

also been observed in

regard to hospital

readmissions.

Bring together community

stakeholders - Create awareness of

the readmissions issue and begin to

address practice patterns that may

contribute to readmissions.

In part due to

different regional

practice patterns,

compared to areas

with fewer hospital

beds, areas with

more hospital beds

may be more likely

to have higher

hospital

readmission rates.

State-specific programs

that (1) bring together

various state-level and

local stakeholders to

identify and apply

community resources;

and (2) partner hospitals

with patients, home

health agencies, SNFs

and outpatient

providers.

Lack of patient

support - Patients who

live alone or have no

access to caregiver

support are more at risk

for a hospital readmission

than those with a support

system.

Improve caregiver engagement

and education to create a

support system for the patient

in the post-discharge setting Enable caregivers to understand and

comply with discharge care plans,

including taking patients to follow-up

physician visits or other

appointments, or by assisting with

patients’ other daily needs.

Assistance

provided by

caregivers may help

prevent the

occurrence of an

adverse event or

the deterioration

of patient health

that may lead to a

rehospitalization.

(1) Educate caregivers

about warning signs of

deteriorating patient

health. (2) Involve

caregivers in discussion

of post-discharge followup needs. (3) Educate

caregivers, along with

patients, about patient

care needs and disease

management.

Medication

discrepancies Medication errors are

some of the most

widespread medical errors

and may be common in

hospitals. Also, surgical

errors have been shown

to be associated with a

higher risk of hospital

readmission.

Establish common personal

health record and reconcile

medication - Provide a tool with

personalized information about

medications used by patient as well

as reconcile pre-hospital visit

medication list with discharge

medication list.

Medication

discrepancies can

lead to adverse

events, which can

lead to an

emergency room

and/or a hospital

readmission.

(1) Perform medication

reconciliation in hospital.

(2) Educate patients

about medications. (3)

Create and use patient

health record. (4)

Maintain telephone

contact (or visit homes

of patient) to address

medication issue.

Source: CRS summary of QIO documents and readmission literature available at http://www.cfmc.org/

integratingcare/toolkit.htm.

As part of the 10th SOW which began August 1, 2011, QIOs will work to reduce

readmissions 20% by 2013 which would prevent the rehospitalization of an estimated 1.6

million hospital patients, among other goals.74 QIOs will also provide technical assistance

to candidates seeking to participate in Community Care Transitions Program (discussed

next) and other communities.75

74

In June, 2011, MedPAC recommended that the QIO program be restructured to give providers (and communities)

increased choice in who can provide technical quality improvement assistance, to increase competition between these

entities, to provide more flexibility in the use of the resources (by direct grants to providers among other changes) and

to increase focus on low-performing providers and communities. MedPAC’s June 2011, Report to Congress: Medicare

and the Health Care Delivery System (subsequently referred to as “MedPAC, “Enhancing Technical Assistance to

Providers” June 2011”).

75

As indicated in the 10th SOW, QIOs will provide technical support for the application process which may include

data analyses and trending reports, interventions selection rationale, and cost estimates for interventions and assistance

(continued...)

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Addressing Medicare Hospital Readmissions

Community-Based Care Transitions Program (CCTP) for High-Risk

Medicare Beneficiaries

Section 3026 of the ACA establishes a five-year community-based care transitions program

(CCTP) for eligible entities beginning January 1, 2011, to test models for improving care

transitions for high-risk Medicare beneficiaries.76 An eligible entity is an IPPS hospital with high

readmission rates77 or certain community based organizations (CBOs)78 that provide care

transition services. Consideration is given to CBOs working with multiple high readmission

hospitals in the community. Preference is given to entities that participate in the care transitions

program administered by the AoA or that provide services to medically underserved populations,

small communities, and rural areas. Consideration is given to physician practices (particularly

primary care practices) that meet the statutory CBO definition, to programs that have established

care management interventions with state Medicaid programs and those who have established

relationships with primary care medical homes serving Medicare beneficiaries (described

subsequently). As noted by CMS, awardees are expected to work closely with accountable care

organizations (ACOs) and medical homes developed in their communities, as it is ultimately the

responsibility of the delivery system to manage care transition and the services needed to support

them.

The goals of the CCTP are to improve transitions of high-risk beneficiaries from the inpatient

hospital setting to other care settings, to improve quality of care, to reduce readmissions for highrisk beneficiaries, and to document measureable savings to the Medicare program. To this end,

Medicare plans to spend $500 million for this five-year program beginning in January 1, 2011.

CCTP may be continued or expanded if the Office of the Actuary (OACT) certifies that the

expansion would reduce Medicare spending without reducing quality.79

(...continued)

with other application requirements. QIOs will also provide assistance for communities that are not accepted into

formal Care Transitions Programs by providing quarterly readmission metrics on various measures (coalition

readmission rates; hospital readmission rates, post-acute care setting readmission rates, disease specific readmission

rates, emergency department visit rates, and observation stay rates and mortality rates).

76

High-risk beneficiaries will be identified using a hierarchical condition category score based on the existence of

multiple chronic conditions, previous substandard transitions into post-hospitalization care, or other readmission risk

factors which may include cognitive impairment, depression, a history of multiple readmissions, or others factors. The

CCTP program is restricted to Medicare FFS beneficiaries including those who are dually eligible (for Medicaid and

Medicare).

77

High readmission hospitals are those with 30-day readmission rates on at least two of the three Hospitals COMPARE

measures (HF, AMI, PN) that fall into the top quartile for their state. A listing of the high readmission hospitals can be

found at http://www.cms.gov/DemoProjectsEvalRpts/downloads/CCTP_FourthQuartileHospsbyState.pdf.

78

Eligible CBOs have a governing body that includes sufficient representation of multiple health care stakeholders

(including consumers) and provide care transition services across a continuum of care though arrangements with IPPS

hospitals. As noted by CMS, CBOs are expected to coordinate across all settings, including hospitals, nursing homes,

home health, SNF, and hospice. “Beneficiaries often experience multiple transitions following discharge from the

hospital and therefore a CBO must follow that beneficiary across various settings if there is any hope of reducing

avoidable admissions.” See https://questions.cms.hhs.gov/app/answers/detail/a_id/10602/related/1.

79

As noted in the CTTP application, participants are expected to reduce Medicare expenditures through the provision

of care transition services which would reduce avoidable hospital readmissions. The application must include

assumptions regarding overall participation rates, rationale and projections of the readmissions to be avoided, and

overall reduction in readmission rates.

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Addressing Medicare Hospital Readmissions

CMS has published a solicitation for applications from entities interested in participating in the

CCTP.80 CCTP applications must describe the root cause analysis that informed the selection of

the proposed intervention and target population. These applications also include information

about the beneficiary notification process which tells them about participation in the program and

information about the applicant’s implementation strategy (including recruitment strategy and

contingency plans for achieving beneficiary participation thresholds). Applicants must have prior

experience with successfully managing care transitions and reducing readmissions. Entities are

awarded a two-year agreement that may be extended—based on their performance—on an annual

basis for the remaining three years. Applicants must provide a budget and a per eligible discharge

rate for transitional care services. Entities selected to participate are paid a per eligible discharge

rate to cover the direct costs of care transition services, and are paid by CMS on a monthly basis

for services delivered in the previous month.81

CMS has selected the Lewin Group, a health care consulting organization, to provide support to

entities selected to provide transitional care services. The Lewin Group and its team will provide

technical assistance and guidance for an estimated 500 CBOs and hospitals expected to be

involved in the project. Lewin will gather best practices through site visits and facilitate peer-topeer information sharing through online collaboration and national meetings.82 On November 18,

2011, CMS made the first seven site selections for CCTP. An additional 23 sites were selected to

participate in CCTP on March 14, 2012.83 Other awards will be issued on a rolling basis until the

$500 million funding ceiling is reached.

The statutory language establishing the CCTP indicated that the care transition interventions

could include (1) initiating transition services no later than 24 hours prior to discharge, (2)

arranging timely post-discharge follow-up to educate patients and caregivers about responding to

their own health symptoms, (3) providing assistance to ensure productive and timely interactions

between patients and post-acute and out-patient providers, (4) providing self-management support

(or caregiver support), and (5) conducting medication review, counseling, and management

support. The intervention may not include payment for discharge planning services required

under Medicare COP.

In the CTTP solicitation, CMS provides information about certain evidence-based care

transitions models that were jointly funded by AoA and CMS. Entities participating in the

program are not required to use these transition models,84 but consideration is given to

applicants proposing to use the following care transition models:85

•

The Care Transitions Initiative (CTI) is a four-week program which provides a nurse

transition “coach” (an advanced practice nurse) to assist patients with complex care

needs, and their families, in being more assertive during care transitions, to have

80

http://www.cms.gov/DemoProjectsEvalRpts/MD/itemdetail.asp?itemID=CMS1239313.

https://questions.cms.hhs.gov/app/answers/detail/a_id/10703/kw/

Community%20Based%20Care%20Transition%20Program.

82

The Lewin Group’s team includes the Colorado Foundation for Medical Care, the University of Colorado, Seamon

Corporation, 371 Productions and ON24.

83

For summary data on the collaborative network, the prior experience, the target population, the service community,

and the implementation strategy of the participants, see http://innovation.cms.gov/initiatives/Partnership-for-Patients/

CCTP/partners.html.

84

https://questions.cms.hhs.gov/app/answers/detail/a_id/10600.

85

https://questions.cms.hhs.gov/app/answers/detail/a_id/10600.

81

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Addressing Medicare Hospital Readmissions

continuity of care across settings, and have their needs met in any care setting.86 In a

randomized controlled trial involving 750 subjects aged 65 and older in a large,

integrated delivery system in Colorado, patients receiving the CTI had lower readmission

rates at 30 days and at 90 days and lower mean hospital costs than those patients without

the CTI intervention.87 In addition, a qualitative review of the results appeared to indicate

improved self-management and confidence about what was required by study participants

who received the intervention.88 A number of hospitals and health systems have

implemented the CTI model, including the implementation of CTI in 2007 in 10

California locations as part of a one-year, $650,000, effort funded by the California

Health Care Foundation.89

•

The Transitional Care Model (TCM) created by a team based at the University of

Pennsylvania (including testing in three completed National Institutes of Health funded

randomized, controlled clinical trials), establishes a transitional care team led by an

advanced practice nurse who has a masters degree in nursing. This transitional care nurse

(TCN) treats a patient before, during, and after discharge from the hospital and

specifically targets chronically ill high-risk older adults.90 In a multi-site randomized

control trial for persons age 65 and older and hospitalized with heart failure, the

intervention TCM group had fewer readmissions in one year following hospital

discharge. The total cost of care for the intervention group was 39% lower per patient

than for the control group.91

•

Project BOOST (Better Outcomes for Older Adults through Safe Transitions) has a

toolkit which aims to improve care transitions for older adults.92 The intervention

sponsored by the Society of Hospital Medicine and the John A. Hartford Foundation,

involves a risk assessment of the patient on eight dimensions with risk-specific

interventions developed to target specific patients.93 The patient’s understanding of his or

her situation as well as readiness to be discharged is assessed at different points during

the hospital stay.94 Project BOOST is associated with improved quality of life, increased

86

See http://www.caretransitions.org/.

Eric A. Coleman, Carla Parry, and Sandra Chalmers et al., “The Care Transitions Intervention: Results of a

Randomized Controlled Trial,” Archives of Internal Medicine, vol. 166 (September 25, 2006), pp. 1822-1828.

88

Carla Parry. Heidi M. Kramer, and Eric A. Coleman, “A Qualitative Exploration of a Patient-Centered Coaching

Intervention to Improve Care Transitions in Chronically Ill Older Adults,” Home Health Care Services Quarterly, vol.

25, nos. 3 and 4 (2006), pp. 39-53.

89

See http://www.chcf.org/topics/view.cfm?itemID=128306. Six of the nine grantees that completed the project had

specific plans to continue the care transitions work when the project ended in September 2008. The CHCF Care

Transitions Projects: Final Progress Report and Meeting Summary, March 2009.

90

See http://www.transitionalcare.info/.

91

Mary A. Naylor, Dorothy Brooten, and Roberta Campbell et al., “Transitional Care of Older Adults Hospitalized

with Heart Failure: A Randomized Clinical Trial,” Journal of the American Geriatrics Society, vol. 52, no. 5 (May 1,

2004), pp. 675-684.

92

http://www.hospitalmedicine.org/ResourceRoomRedesign/RR_CareTransitions/PDFs/

Workbook_for_Improvement.pdf.

93

The 8P is an eight component screening tool that evaluates (1) problem medications, (2) psychological needs, (3)

principal diagnosis, (4) polypharmcy (the potential for adverse reactions when a patient takes multiple drugs); (5)

health literacy, (6) patient support, (7) prior hospitalizations, and (8) need for palliative care.

94

The patient is evaluated in two domains: logistical issues and psychosocial issues using the general assessment of

preparedness (GAP) Tool. Depending upon the question, the assessment occurs at admission, prior to discharge, or at

discharge.

87

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Addressing Medicare Hospital Readmissions

involvement and satisfaction with hospital discharge care and improved communication

between the hospital and physicians.95

•

Re-Engineered Design (RED) consists of a set of 11 actions taken primarily during a

hospital stay by discharge advocates (registered nurses) to address care transition

elements.96 In a study involving Project RED, 370 patients participating in the project

were one-third less likely to be readmitted to the hospital or visit the emergency

department than patients who did not participate in the project. Compared to roughly onethird of patients not in the project who left the hospital with a follow-up appointment,

almost all project participants had an appointment at that time. Also, more than 90% of

participants’ primary care physicians received patient discharge information within one

day of leaving the hospital. Medication review by pharmacists of project participants also

successfully identified a number of medication errors.97 and

•

Transforming Care at the Bedside (TCAB) was created through a partnership between the

Institute for Healthcare Improvement and the Robert Wood Johnson Foundation in 2003

in order to address safety and quality of patient care in hospitals and to improve staff

satisfaction. One aspect of TCAB addresses transitional care and encompasses (1)

assessing the patient’s post-discharge options at the time of hospital admission; (2)

educating the patient and family caregiver and confirming their understanding of

discharge instructions; (3) providing medication information to outpatient providers seen

after leaving the hospital; and (4) scheduling post-acute care follow-up for high-risk

patients,98 or providing a follow-up phone call and scheduled physician office visit to

moderate risk patients.99 An assessment found the intervention was associated with

reductions in patient wait times and an increase in patient and staff satisfaction, among

other benefits.100

Generally, these models aim to provide (1) care coordination between the hospital and posthospital settings and providers; (2) education of patient and family caregivers; (3) follow-up

95

David Preen, Belinda E. S. Bailey, Alan Wright, Peter Kendall, Martin Phillips, Joseph Hung, Randall Hendriks,

Annette Mather, and Elizabeth Williams, “Effects of a Multidisciplinary, Post-discharge Continuance of Care

Intervention on Quality of Life, Discharge Satisfaction, and Hospital Length of Stay: A Randomized Controlled Trial.”

International Journal for Quality in Health Care, vol. 17, no. 1 (2005), pp. 43-51.

96

See http://www.bu.edu/fammed/projectred/. Louise is a virtual nurse or discharge advocate that runs on a touch

screen display as part of a bedside patient education system that is also part of the RED toolkit.

97

Brian W. Jack, Veerappa K. Chetty, and David Anthony et al., “A Reengineered Hospital Discharge Program to

Decrease Rehospitalization,” Annals of Internal Medicine, vol. 150, no. 3. (February 3, 2009), pp. 178-187.

98

A high-risk patient is defined as one who has been admitted two or more times in the past year and failed teach back

(could not recall or repeat discharge instructions) or as someone whose family caregiver has a low degree of confidence

to carry out self-care at home. Self-care includes weighing self, maintaining diet or adhering to medications, and

accessing food, transportation, and medications.

99

A moderate risk patient is defined as one who has been admitted once in the past year and as someone whose patient

or family caregiver has a moderate degree of confidence to carry out self-care at home. Gail A. Nielsen, Annette

Bartely, Eric Coleman, Roger Resar, Pat Rutherford, Dan Souw, and Jane Taylor. Transforming Care at the Bedside

How-to Guide: Creating an Ideal Transition Home for Patients with Heart Failure. Cambridge, MA: Institute for

Healthcare Improvement; 2008. Although the guide addresses the creation of transition homes for patients with heart

failure, it is presented as adaptable for patients with other conditions.

100

Holly L. Lorenz, Pamela K. Greenhouse, Rosemary Miller, Mary K. Wisniewski, and Susan L. Frank,

“Transforming Care at the Bedside: An Ambulatory Model for Improving the Patient Experience,” The Journal of

Nursing Administration, vol. 38, no. 4, (April 2008), pp. 194-199.

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Addressing Medicare Hospital Readmissions

monitoring of a patient’s health status after discharge; and (4) care from a transitional coach or

team to manage clinical, psychosocial, rehabilitative, nutritional, and pharmacy needs after

discharge. The scope of the intervention (and therefore the associated costs) with respect to

patients targeted, as well as the duration and types of services involved, will vary by care

transition model. Table 2 summarizes key features of the five different care transition models.

Table 2. Key Features of Five Different Care Transition Models

Program focus

Care

Transitions

Initiative (CTI)

Transitional

Care Model

(TCM)

“Coleman

Model”

“Naylor

Model”

Project

BOOST

Patient/caregiver

coaching and

education. Patient

self-management.

Discharge

management and

follow-up.

In-hospital and

discharge

management and

follow-up.

ReEngineered

Design (RED)

Transforming

Care at the

Bedside

(TCAB)

Creating an

Ideal

Transition

Home

Discharge

management and

follow-up.

Discharge

management.

Patient selfmanagement and

follow-up.

Patients Targeted

Age

Age 65 and older

(may be applied to

younger adults).

Age 65 and

older.

At least 18 years

old, with a focus

on older adults.

No age

specified.

No age

specified.

Risk factors and

other patient

characteristics

Have at least one

of 11 diagnoses.

2 or more risk

factors: recent

hospitalizations,

multiple chronic

conditions, or

poor self-health

ratings.

Identifies high

risk patients

using 8P

screening tool at

admission.

Not discussed.

Moderate-risk

and high-risk

patients with

congestive heart

failure (but can

be adapted and

generalized to

other patient

populations).

Cognitive ability

assessed on

admission. If

dementia is

present, then a

reliable

caregiver is

required.

Not discussed.

Patient

assessment on

admission,

including

cognitive status.

Goal is to

identify

learner(s) who

can be either

patient or

caregiver.

English speaking

with working

telephone.

Planned discharge

to home or SNF

(not long-term

care).

Assessment of

cognitive ability

and ability to

participate in

intervention

Cognitive ability

and mental state

determined

through mental

health screen. For

patients who fail

or if dementia is

present, a willing,

reliable caregiver

is required.

Congressional Research Service

Patient’s home is

primary care

setting (testing

TCM on longterm care

recipients).

Cognitively

intact patients

are required

(are now testing

TCM on

cognitively

impaired older

adults).

20

Addressing Medicare Hospital Readmissions

Care

Transitions

Initiative (CTI)

Transitional

Care Model

(TCM)

“Coleman

Model”

“Naylor

Model”

Project

BOOST

ReEngineered

Design (RED)

Transforming

Care at the

Bedside

(TCAB)

Creating an

Ideal

Transition

Home

Program Scope

Length of

program

4 weeks.

1-3 months.

Hospital

admission up to

72 hours after

discharge.

Hospital

admission up to

72 hours after

discharge.

Hospital

admission up to

5 days following

discharge.

Staff or team

involved

Transitions

“coach” does not

provide skilled

care.

Transitions care

nurse (TCN) is

an advanced

practice nurse

(APN) with

masters degree

and a caseload

of 15-20

patients.

No explicit care

coordinator.

Team approach

among clinical

nursing staff,

hospitalists

(physicians who

specialize in the

practice of

hospital

medicine) and

other hospital

staff.

Trained

registered nurse

(“discharge

advocate”)

coordinates

discharge plan

with the hospital

team.

Teams of 5-7

people, including

front-line staff

(nurses,

physicians, and

pharmacists) and

patients or

caregivers to

create hospital

program; APN

makes follow-up

phone calls.

Patient

education

Educates patients

or caregivers

about medications

and personal

health record.

Provides

information about

signs of

deteriorating

conditions and

appropriate

follow-up actions.

Educates

patients and

caregivers to

identify (and

meet) health

goals and

manage care.

Nurse discusses

medication and

discharge

instructions with

patient and

family.

Uses teach-back

methoda with

patients and

caregivers to

discuss

medications,

diagnosis,

prognosis, and

self-care, as well

as to educate

about warning

signs requiring

further medical

attention.

Provides

education

throughout the

hospital stay.

Explains

medication plan.

Educates patient

about medical

emergency

options.

Assesses

patient’s grasp

of the discharge

plan and followup care.

Uses teaching

materials

(written, visual,

audio, and faceto-face) and uses

teach-back

methods every

day to educate

patient and

families about

critical

information

needed after

discharge.

In-hospital

services

One visit to help

patient manage

transition out of

hospital.

Assessment

within 24 hours

of TCM

enrollment.

Daily visits

throughout stay.

At different

points of stay,

patients are

assessed using

general

assessment of

preparedness

(GAP) tool to

see if they are

ready for

discharge.

Contact

throughout the

hospital stay.

Intervention

begins in the

hospital on the

first day of

admission and

continues every

day during

hospitalization.

Discharge

planning plan or

checklist

Provides personal

health record

(PHR) with

structured

discharge

Provides written

plan with

instructions and

phone numbers

for emergency

Provides

patients with

clear,

understandable

written

Evaluates

discharge plan

compared to

national

guidelines. Gives

Designates team

member

accountable for

effective

discharge of

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Addressing Medicare Hospital Readmissions

Care

Transitions

Initiative (CTI)

Transitional

Care Model

(TCM)

“Coleman

Model”

“Naylor

Model”

Project

BOOST

ReEngineered

Design (RED)

Transforming

Care at the

Bedside

(TCAB)

Creating an

Ideal

Transition

Home

checklist.

care.

discharge

instructions that

have reminders

of what patients

must do to care

for themselves

following

discharge.

the patient a

written

discharge plan

with

hospitalization,

medication, and

follow-up care

information.

each patient.

Gives patient

discharge

checklist.

Post-discharge

follow-up

services with

patient

Follow-up visits to

SNF and/or the

home. Telephone

calls.

TCN visit in

home within 2448 hours of

discharge and at

least weekly

during the first

month following

discharge, and at

least semimonthly during

the rest of the

intervention;

daily telephone

availability.

Telephone

contact within

72 hours of

discharge.

Ensures followup appointment

with aftercare

medical provider

within 7 days.

Arranges

transportation

to initial follow

up.

Telephone

contact 2-3 days

after discharge

to reinforce

discharge plan

and help with

any problems.

Prior to

discharge: for

high risk

patients,

schedule faceto-face visit

within 48 hours

after discharge;

for moderate

risk patients,

follow-up phone

call within 48

hours and

physician visit

within 5 days.

Assistance with

planning followup services or

treatment or

communication

with post

hospital

providers.

Emphasize

importance of

follow-up

physician visit;

prepare for visit

using role-playing.

Coach follows up

with primary care

provider or

specialist following

patient visit with

provider or

specialist.

TCN

accompanies

patient on first

post-discharge

physician visit

and, if needed,

on subsequent

visits.

Hospitals

confirm that

patient’s

principal

outpatient

provider

receives

discharge

summary.

Suggests

communicating

discharge

summary

information to

other post-acute

providers.

Makes

appointments

with clinicians

and for postdischarge

laboratory

testing and

other services.

Coordinates

appointments

and helps

patients keep

these

appointments.

Provides

outpatient

physicians with

discharge

summaries,

medication lists,

list of patient

medical issues,

including test

results.

Provides patient

information

(discharge

summaries) to

next care

providers within

one day of

discharge. Prior

to discharge,

schedules an

office visit for

moderate and

high-risk

patients.

Medication

management

services

In-hospital

medications are

discussed with

TCN discusses

medications

with hospital

Medications are

reconciled at

admission,

Reconciles the

discharge

medication plan

Reconciles

medications on

admission and

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Addressing Medicare Hospital Readmissions

Written

documentation

of patient’s

treatment,

conditions and

plan of care at

discharge

Transforming

Care at the

Bedside

(TCAB)

Creating an

Ideal

Transition

Home

Care

Transitions

Initiative (CTI)

Transitional

Care Model

(TCM)

“Coleman

Model”

“Naylor

Model”

Project

BOOST

patient and at

home visit

medication lists

are reconciled.

Intervention

focuses on

medication selfmanagement by

patient.

Medication list

provided in PHR.

pharmacist and

other providers.

TCN reconciles

medication upon

patient discharge

from hospital.

during inhospital

transfers and at

discharge.

Medication use

and side effects

are reviewed

with patients.

with prior

medication plan.

Medication use

and side effects

are discussed.

Plan for

acquiring

medications is

discussed with

patient.

discharge.

Evaluates

withheld

medications to

decide if

necessary to

restart. Provides

new medication

list and assesses

patient’s

understanding of

list.

PHR includes

patients medical

history,

medications

(dosages) and

allergies, list of

warning signs or

“red flags” (drug

reactions and signs

of worsening

condition).

Each patient and

primary care

provider of the

patient receives

a summary of

the patient’s

transition, at the

end of the TCM

intervention.

Principal care

providers

receive

discharge

summary.

Patients receive

printed

reminders of

post-discharge

care plan.

Patients are

given a written

discharge plan.

Transition

report assesses

patient’s ability

to engage in

various self-care

activities.

Patients are

given phone

numbers to call

for help, reasons

to request help,

and self-care

instructions.

ReEngineered

Design (RED)

Source: CRS summary of information from care models’ websites provided in above descriptions.

a.

Teach back involves asking patients to recall and restate what they have been told.

Among other goals, CCTP seeks to document whether Medicare can realize measurable program

savings by paying for care transition services. Evaluations of the earlier Medicare Care

Coordination Demonstration (MCCD)101 or the Medicare Health Support (MHS) Pilot

Program102did not find that care coordination programs resulted in clear improvements to patient

101

Established by the Balanced Budget of 1997, 15 care coordination programs for chronically ill FFS Medicare

beneficiaries were started in 2002.The end dates for 11 of the 15 programs were extended from 2006 to 2008; Two of

the 11 were further extended through March, 2010, because of their potential for achieving cost neutrality.

http://www.cms.gov/DemoProjectsEvalRpts/MD/itemdetail.asp?filterType=none&filterByDID=0&sortByDID=3&

sortOrder=descending&itemID=CMS1198864&intNumPerPage=2000. Only two programs had a statistically

significant effect on the annual number of hospitalizations. No program reduced Medicare program expenditures. The

interventions did not systematically improve process measures of quality of care or patients’ health behaviors. Deborah

Peikes, Arnold Chen, Jennifer Schore, and Randall Brown, “Effects of Care Coordination on Hospitalization, Quality

of Care, and Health Care Expenditures Among Medicare Beneficiaries: 15 Randomized Trials” JAMA, vol. 301, no. 6

(2009), pp. 603-618. (Subsequently referred to as Peikes et al., “Effects of Care Coordination.”)

102

Established by MMA, starting in 2005, the MHS Program tested different care management interventions to

improve clinical quality of care and beneficiary/provider satisfaction as well as achieving cost savings for chronically

ill Medicare FFS beneficiaries with congestive heart failure or diabetes. Designed in two-phases, after a three-year

period, the program or any of its components could be expanded if evaluated as successful according to established

(continued...)

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quality of care or lower Medicare’s costs. Still, an examination of the more successful MCCD

participants indicates that care coordinators should interact with patients in person rather than by

telephone only and should collaborate closely with patients’ physicians to influence their care.103

At this point, experts suggest that the most effective intervention for care coordination with

respect to cost savings and quality improvement would include a proven care transitions

program.104 However, hospitals or other entities may face certain difficulties in implementing or

sustaining care transitions initiatives. Patient participation rates in these programs have been low,

as a substantial proportion of patients were not interested in enrolling in the transitions programs

or receiving home visits.105

One study found that exposing heart failure patients to a transitions program led to a nearly 50%

reduction in 30-day readmission rates. Looking at the program expenditures, hospital costs and

patient revenues, the study found that the contribution of each patient to the hospital’s profit

margin was reduced by $227 using a care transitions program, compared to the status quo.106

Each participating hospital lost roughly $750 of revenue on average for each patient participating

in the program.107 The authors speculate that even after implementation of the readmission

penalties, hospitals still would not have a financial incentive to pay for transitions programs. In

their view, potential future payment reforms, such as bundled payments or payment based on

(...continued)

measures and conditions. CMS discontinued the program in 2008 after a preliminary evaluation of 18-month interim

results. See https://www.cms.gov/CCIP/02_Highlights.asp and https://www.cms.gov/reports/downloads/

MHS_Second_Report_to_Congress_October_2008.pdf.

103

Also, in order to achieve reduced hospitalizations, the programs may want to target patients with intermediate

average costs, not those who are relatively healthy or extremely sick. J. Z. Ayanian. “The Elusive Quest for Quality and

Cost Savings in the Medicare Program’” JAMA, vol. 301, no. 6 (2009), pp. 668-670. This was also a lesson from MHS

program. Michael Barr, Sandra Foote, Randall Krakauer, and Patrick Mattingly, “Lessons for the New CMS Innovation

Center from the Medicare Health Support Program” Health Affairs, 29 No. 7 (2010); 1305-1309.

104

Peikes et al., “Effects of Care Coordination.” Also, Rachel Voss, Rebekah Gardner, Rose Baier, Kristen Butterfield,

Susan Lehrman, and Stefan Gravenstein, “The Care Transitions Intervention: Translating from Efficacy to

Effectiveness,” Archives of Internal Medicine, vol. 171, no. 14 (July 2011), pp. 1232-1237. (Subsequently referred to as

the Voss study) In this study, Medicare patients who participated in the month-long intervention had 30-day

readmission rates of 13% while those who did not participate in the intervention had readmission rates of 20%.

105

In the Voss study, 55% of patients agreed to participate in the intervention and 14% agreed to a home visit. Low

participation rates also affected the care coordination programs participating in the MCCD. Peikes et al., “Effects of

Care Coordination.”

106

Under the current payment system and typical intervention, the average episode of care costs per patient was

determined to be $6,780, while the revenue was $8,196, for a contribution margin of $1,436. With the care transitions

program, the episode of care costs was slightly lower, $6,236, while the revenue for the episode of care was also lower,

$7,445, for a contribution margin of $1,209. The difference ($1,436-$1,209) in contribution margin was then $227. See

Brett Stauffer, Cliff Fullerton, Neil Fleming, Gerald Ogola, Jeph Herrin, Pamala Martin Stafford, and David J. Ballard,

“Effectiveness and Cost of a Transitional Care Program for Heart Failure,” Archives of Internal Medicine, vol. 171, no.

14 (July 2011), 1238-1243.(Subsequently referred to as Stauffer et al., Effectiveness and Cost of a Transitional Care

Program for Heart Failure (2011)).

107

A hospital’s financial benefit from a rehospitalization could depend upon whether it had excess bed capacity. One

study found that the average length of stay for rehospitalized patients was 0.6 day more than that for comparable

patients whose most recent rehospitalization had been at least 6 months previously; although the hospital incurred

higher costs when treating rehospitalized patients, Medicare’s payments would be approximately the same for both sets

of patients. There might be as much financial benefit from rehospitalizations as first time admissions for a hospital with

excess capacity, but not other hospitals. Jencks, Williams, and Coleman, “FFS Medicare Rehospitalizations,” NEJM,

vol. 360 p. 1427.

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episodes of care, may be necessary to encourage integration of the delivery system along with the

effective use of coordination of care and improved transitional care programs.108

These conclusions were supported in a cost analysis of different clinical interventions and a

simulation of alternative payment incentives using data from New York state.109 Generally, a

hospital’s response would depend both on its circumstances and the payment incentives

established by the different payors.110 The study examined pay-for-performance (P4P) and

episode-based payments. The P4P simulation assumed that each hospital would receive a reduced

payment if its readmissions exceeded a benchmark. With this payment design, a payer would

retrieve savings immediately even if hospital behavior did not change because low-performing

providers were paid less when they exceeded the benchmarks. High-performing hospitals’

payments were not adjusted. Although high performers have no financial incentive to reduce

readmissions further, low-performing hospitals were seen as having the greatest potential for

reducing aggregate readmissions. In this simulation however, only 7% of low-performing

hospitals respond to the payment penalty by implementing a program, such as CTI or Project

RED, to reduce readmissions.111 As discussed in the next section, the financial incentives for

episode-based payments are markedly different than bundled payments under FFS. Under

episode-based payment structures as modeled in the simulation, at least half of the hospitals in

New York state could be motivated to implement either CTI or Project RED.

Forthcoming Medicare Payment Initiatives to

Address Readmissions

As well as establishing CCTP to assist certain high readmission hospitals with care transitions,

ACA included several payment initiatives to encourage FFS providers, particularly hospitals, to

work to minimize rehospitalizations, if not coordinate patient care across settings. This section

will discuss the Hospital Readmission Reduction Program (HRRP), the national pilot program

included in ACA, and the national bundled payment pilot program established by the Center for

Medicaid and Medicare Innovation (CMMI).112

108

In the study by Stauffer noted above, bundled payments would both improve the quality of care for patients and pay

for the transitional care programs. However, the bundled payment amount for the index discharge would need to be set

higher than current reimbursement rates to appropriately fund these programs. Stauffer et al., Effectiveness and Cost of

a Transitional Care Program for Heart Failure (2011).

109

Reducing Hospital Readmissions in New York State: A Simulation Analysis of Alternative Payment Incentives,

Mathmatica Policy Research, September 2011.

110

The study examined pay-for-performance (P4P) and episode based payments. The P4P simulation assumed that each

hospital would receive a reduced payment if its readmissions exceeded a benchmark. Under episode-based payments

the hospitals would receive an enhanced payment for a patient’s initial admission, but no payments for subsequent

admissions within 30 days.

111

This appears to be an obstacle for other care transitions programs as well. In fact, one component of Project BOOST

(discussed earlier) is designed to help advocates for that program establish at least a revenue-neutral business case for

the adoption of that intervention by the hospital See Project BOOST: A Return on Investment Analysis found

http://www.hospitalmedicine.org/ResourceRoomRedesign/RR_CareTransitions/PDFs/BOOST_ROI_Paper.final.pdf.

112

The hospital Value-based Purchasing (VBP) program which will redistribute Medicare payments from lowperforming hospitals to high-achieving or improving hospitals based on certain performance measures starting October

1, 2012, is outside the scope of this discussion; readmission measures cannot be included as part of that program. As

directed by statute, hospital scores in the VBP program will include an efficiency measure starting in FY2015 that will

assess hospital performance based on Medicare spending per beneficiary. This measure will include all spending on

(continued...)

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The Hospital Readmissions Reduction Program (HRRP)

Section 3025 of ACA establishes the HRRP which will reduce Medicare’s payments to hospitals

with higher than expected readmission rates starting for discharges on October 1, 2012.113 In

FY2013 and FY2014, CMS has been directed to select high-volume and high-expenditure

conditions that have readmission measures that are endorsed by NQF. In FY2015, the

readmission measures will be expanded (to the extent practicable) to include the additional four

conditions identified by MedPAC in its June 2007, Report to Congress and to other appropriate

conditions.114 For those measures, the Secretary may use measures without NQF endorsement as

long as due consideration is given to any endorsed measures. Under the program, acute-care

hospitals with excess readmissions will have their base operating DRG payment amounts (for all

Medicare discharges) reduced by an adjustment factor.115 The adjustment factor selected is the

one that would result in the least amount of penalty for the hospital. Specifically, the HRRP

adjustment in a fiscal year will be the greater of: (1) a floor adjustment factor of 0.99 in FY2013;

0.98 in FY2014 and 0.97 in FY2015 and beyond or (2) an excess readmissions ratio based on a

hospital’s adjusted actual or predicted readmissions versus adjusted expected readmissions (which

is used to calculate the amount of excess payments for the applicable conditions and then divided

by the hospital’s total operating base payments for Medicare to derive a penalty percentage).

MedPAC has estimated that the aggregate HRRP penalties will be approximately 0.2% of

Medicare’s IPPS payments in 2013.

CMS is implementing this program over two years. In the FY2012 IPPS rate-setting process,

CMS finalized the readmission measures and related methodology, the calculation of the

readmission rates, and the public reporting of the data. While the 2012 rule included a general

discussion of the payment adjustment model, specific information regarding the payment

adjustment will be included in next year’s IPPS rule. In FY2013, the program will include three

readmissions measures for Medicare inpatient hospital readmissions involving three high-volume

and/or high-rate conditions, PN, AMI, and HF, which account for approximately 12% of all

Medicare admissions. As endorsed by NQF, Medicare’s time frame for a readmission is 30

days.116 As CMS stated, a 30- day timeframe incorporates “a substantial proportion of

readmissions attributable to an index [or initial] hospitalization” and is short enough so that

hospitals and other community entities would be able to improve patient outcomes with

(...continued)

hospital patients from three days before admission to 30 days after discharge, including Medicare spending on any

rehospitalization. In this respect, the VBP program may provide a general incentive for hospitals to devise and

implement strategies to avoid their patients’ readmissions.

113

Section 3025 of ACA also establishes a program, to be administered by the Agency for Healthcare Research and

Quality, where patient safety organizations (PSOs) work with high readmission hospitals to improve their readmission

rates by March, 2012. See http://www.pso.ahrq.gov/readmin/readmin.htm#general for additional information.

114

MedPAC identified chronic obstructive pulmonary disease, coronary artery bypass graft surgery, percutaneous

transluminal coronary angioplasty and other vascular procedures in addition to PN, HF, and AMI as accounting for

almost 30% of potentially preventable readmissions.

115

The base operating DRG payment amount is determined without regard to the hospital value-based purchasing

program and also excludes outlier, IME, DSH, and low-volume hospital payments. Statutory language indicates that

hospital-specific payments for sole community hospitals (SCHs) are exempt and payments for Medicare dependent

hospitals (MDHs) are exempt for discharges occurring during fiscal years 2012 and 2013. The MDH hospital status

will expire on October 1, 2012.

116

Each rehospitalization during the 30 days following an index admission is considered a readmission, rather than

another index admission. However, patients with multiple readmissions are only counted once.

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appropriate hospital care and transitional care.117 For the FY2013 hospital readmission program,

CMS will assess hospital performance on readmissions using a three-year measurement period

(the applicable period) starting in July 1, 2008 through June 30, 2011. IPPS hospitals with a small

number of cases in the selected conditions (less than 25 cases in three years) would not be subject

to the HRRP penalty (but their cases would be included in the national data). Critical access

hospitals and other IPPS exempt hospitals will not be subject to the readmission penalty.118 As

noted earlier, CMS did not propose specific policies with respect to the HRRP payment

adjustment in the FY2012 rule, but did receive public comments on certain issues. (See the

discussion of the CMS’ all-cause measure in Appendix B for additional information on

implementation issues raised during the FY2012 IPPS public comment period.)

HRRP’s risk-adjustment is intended to control for differences across hospitals in patient

characteristics. Some contend, however, that certain factors affecting readmissions are not

accounted for in the existing risk adjustment and that some hospitals may find it more difficult

than others to reduce readmission rates. Because of the patients that they treat or due to other

factors, hospitals with more complex patient populations or those in certain locations, may have

greater difficulty than other hospitals in responding to high readmission rates.119 Some fear that

these hospitals may have limited resources to spend investing in strategies to reduce preventable

readmissions. This problem may be compounded because the payment penalty applies to only

hospitals and not to other providers that may care for a patient following a patient discharge.120

Finally, hospitals may be located in areas where access to post-acute care or supportive services

within the community following a hospitalization (during the time period for measuring

readmissions) is limited and thus hospitals treating patients in those areas may be less able to

prevent readmissions.

Other factors confronting hospitals may compete with HRRP’s incentives to reduce readmissions.

First, hospitals will continue to be paid for each readmission; despite the payment penalty applied

to the per discharge Medicare reimbursement, hospitals can potentially reduce losses from the

penalty with income from the readmissions. Second, there are annual caps on the payment

penalty, which could create an incentive for some hospitals to limit their investments in patient

safety and other readmission reduction strategies if the costs of such investments are greater than

117

CMS noted that the 30-day time frame “is a clinically meaningful period for hospitals, in collaboration with their

medical communities, to reduce readmission risk. This time period for assessing readmission is an accepted standard in

research and measurement. We believe that during this 30-day time period, hospital and community partners can take

steps to reduce risk by ensuring patients are clinically ready to be discharged, improving communication across

providers, reducing risks of infections, and educating patients on symptoms to monitor whom to contact with questions

and where and when to seek follow-up care can influence readmission rates.” See pp. 51669-70 of the Federal

Register, August 18, 2011, vol. 76, no 160.

118

The Secretary may exempt Maryland hospitals (paid under a Medicare waiver) if the state has a comparable costsavings program. As discussed in the proposed FY2013 IPPS rule published in the Federal Register on May 11, 2012,

Maryland has established a Admission-Readmission Revenue (ARR) Program effective July 1, 2011. CMS will

evaluate that voluntary program and determine whether it meets the criteria to exempt Maryland hospitals from HRRP.

119

“Only a small percentage of 30 day readmissions are probably preventable, and much of what drives hospital

readmission rates are patient- and community-level factors outside the hospital’s control.” Karen Joynt and Ashish Jha,

“Perspective: Thirty-Day Readmissions—Truth and Consequences,” NEJM, (March 28, 2012).

120

In March 2012, MedPAC recommended that Medicare payments to SNFs with relative high risk-adjusted

rehospitalizations be reduced. Once the risk-adjusted measures have been established, MedPAC recommends that the

policy be expanded to cover 30 days after discharge so that SNFs would be encouraged to adopt effective care

transitions for patients going home. They contend that these policies will better align hospitals’ and SNFs’ incentives to

reduce rehospitalizations. MedPAC’s March 2012, Report to Congress: Medicare Payment Policy, p. 199.

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the potential payment penalty.121 Third, hospitals may be able to change coding practices, alter

transfer policies or use of outpatient observation to avoid countable readmissions. For instance,

hospitals could change coding practices to avoid identifying patients with AMI, HF, or PN;

alternatively, hospitals might have increased incentives to transfer such initial admissions to other

hospitals or readmit such patients on an outpatient basis for observation services rather than

rehospitalize them.122 Fourth, since the initial readmission rate is based only on three conditions,

hospitals may elect to target Medicare patients admitted with those diagnoses (in order to

minimize resources expended and perhaps any associated reduction in patient volume) rather than

adopting a broadly based care transition program across all conditions and all patients. Finally,

the emphasis on preventing readmissions, although laudable, may come at the expense of other

quality improvement or patient safety efforts.

The final sections of this report will briefly describe the National Payment Bundling Pilot

Program included in Section 3023 of ACA and then discuss the Bundled Payment for Care

Improvement Initiative announced by CMMI.

National Pilot Program of Payment Bundling

Under a bundled payment method, a single payment is made for a defined group of services

rather than individual payments for each service. Depending upon the scope of services included

in the bundle, it may be used to pay for items or services furnished by a single provider or those

furnished by several providers in different health care settings. Bundled payments are

increasingly seen as a way to move away from the existing FFS incentives and to reduce

Medicare costs, increase coordination of care, and improve the quality of care.123

As established by Section 3023 of ACA, beginning no later than January 1, 2013, a voluntary

pilot program will pay a single health care entity for all services delivered during an entire care

episode centered on a hospitalization. CMS has deferred implementation of this national pilot

program, so few details about its design are available. Moreover, the statutory language provides

only general guidance about the design of the pilot program and leaves many implementation

decisions to the Secretary such as:

•

Which entities can receive bundled payments?

•

What is an effective payment design and rate-setting method?

•

What period of time after a hospitalization should constitute an episode?

121

If a hospital is subject to the readmission penalty, Medicare payments for all discharges during the fiscal year will

be reduced. The size of the aggregate penalty in any hospital would depend upon the number of Medicare patients

served. A hospital with a high Medicare patient load would have a larger financial incentive to dedicate additional

resources to preventing readmissions.

122

In the FY2012 IPPS final rule, CMS stated that it will monitor admissions and readmissions to ensure that there is

no systematic shift in patients’ primary discharge diagnosis; CMS will consider future monitoring of transfer rates to

see if there are unexpected changes in transfer rates. CMS did not mention monitoring trends in observation services

provided in hospital outpatient departments.

123

The Congressional Budget Office has summarized the results from the Medicare Participating Heart Bypass Center

Demonstration. The demonstration tested bundled hospital and physician payments for coronary artery bypass graft

surgery in select hospitals starting in the early 1990s. See pp. 15-28 of Lessons from Medicare’s Demonstration

Projects on Value-Based Payment, Congressional Budget Office Working Paper 2012-02, January 2012, at

http://www.cbo.gov/ftpdocs/126xx/doc12665/WP2012-02_Nelson_Medicare_VBP_Demonstrations.pdf.

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•

What additional services should be included in the bundle?

•

What medical conditions should be included in the pilot?

•

How should quality of care be measured?

•

What constitutes an adequate post-acute provider referral network? and

•

What patient assessment instrument should be used?

The statutory language defines a care episode as three days prior to a hospital admission, the

hospital stay, and the first 30 days following discharge (unless another time period is selected). In

addition to Medicare’s traditional acute and post-acute services,124 participating providers will be

expected to deliver care coordination, medication reconciliation, discharge planning, transitional

care services and other appropriate services. The pilot can cover up to 10 conditions which may

include a mix of chronic or acute conditions, or surgical or medical conditions. The selected

conditions might be those with a significant variation in readmission or post-acute spending or

those with high volume and high post-acute spending. These conditions might be deemed most

suitable for bundled payments across the spectrum of care given the range of practice patterns or

those where evidence indicates that costs could be reduced without affecting quality.

The pilot’s payment methods may include bundled payments and bids from entities for episodes

of care. An appropriate patient assessment instrument to evaluate the beneficiary’s condition and

ensure the most clinically appropriate post-acute site for care will be used in the pilot. Site neutral

quality measures for an episode of care and for post-acute care will be developed.125Also,

participating entities must provide an adequate choice of providers and suppliers to beneficiaries.

However, payments for all services provided during the episode must meet a budget neutrality

standard; spending cannot exceed an estimate of what would otherwise have been spent on these

beneficiaries in the absence of the pilot. Finally, if the Secretary determines that the expansion of

this program would reduce Medicare spending without reducing quality of care and the Chief

Actuary for CMS certifies that such an expansion would reduce Medicare spending, the duration

and scope of the pilot can be expanded after January 1, 2016.

Bundling payments for acute and post-acute care has the potential to reduce costs without

compromising outcomes by changing some of the incentives within FFS Medicare. An entity’s

financial returns will be higher if the patient is discharged to the community earlier or uses the

least costly post-acute care setting. Since the entity bears the financial risk of both a readmission

and the costs of all post-acute care, there is a strong incentive to coordinate care across settings,

provide necessary post-acute care in the least expensive setting and not discharge patients

prematurely. However, identifying a mix of providers that will agree to share payments may be

challenging for that entity, unless provider groups are already organized under a single umbrella

entity. Further, whether and how well providers can deliver coordinated care across an episode

remains unclear. With bundled payments, there are strong incentives to take an active role in

monitoring the provision of post-hospital care which could lead to unintended adverse

124

The ‘applicable services’ are acute care inpatient services, physicians’ services delivered in and outside of an acutecare hospital, outpatient hospital services including emergency department services, post-acute services, including

home health, skilled nursing, inpatient rehabilitation, long-term care hospital inpatient services, and other services.

125

Quality process, outcome and structure measures will be established to assess: functional status improvement, the

reduction of avoidable hospital readmissions, the rates of discharges to the community, the rates of post-hospitalization

emergency room admissions, the incidence of health care acquired infections, efficiency measures, measures of patientcenteredness of care, measures of patient perception of care and others.

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consequences with respect to limiting access to necessary post-acute care or restricting patients’

choice of post-acute providers.126 Moreover, bundled payments alone would not necessarily create

an incentive to lower the volume of patients served because hospitals and providers could profit

from additional episodes of care.

Bundled Payment for Care Improvement Initiative

CMS has made implementation decisions with respect to a separate payment bundling effort.

Under its authority to test innovative payment and service delivery models, CMMI issued a

request for applications in August 2011, for its Bundled Payments for Care Improvement

Initiative (Bundled Payment Initiative). The three-year project starting in 2012 will encompass

four different bundled payment models.127 Generally, CMS will make one payment for the

services a Medicare beneficiary receives during an episode of care. The eligible awardees

(participating organizations), eligible suppliers and providers, scope of services included in the

episode, and payment methods vary by model. Subject to certain standards, a participating

organization may determine the conditions, length of an episode of care, target price, discount and

other organizational components, including participating suppliers and providers. All models are

subject to a post-episode monitoring period to ensure that that aggregate Medicare Parts A and B

spending for the included beneficiaries does not increase as a result of the initiative; the awardees

will pay Medicare for aggregate expenditures that exceed the trended baseline spending (based on

historic claims experience including ‘‘risk threshold” set by CMS).128 Three of the models use a

retrospective bundled payment method where the participating providers and suppliers are paid

for services at a negotiated discount. Two of those models will compare those payments to a

target price. If below the target, the awardees may share the savings with their participating

providers. If above the target, the awardees will remit the difference to CMS. In the fourth model,

the participating organization will be paid a single prospectively determined bundled payment for

the episode. Generally, all bundled payment models will permit gainsharing arrangements where

participants will be able to share any financial benefits that occur because of the efficiencies that

result from better coordinated care.129 Mandatory participation in any gainsharing arrangement is

not permitted.130

126

A hospital that is the entity receiving the bundled payment may reduce the number of post-acute providers in its

referral network or may increase the use of in-hospital post-acute units to reduce costs or minimize administrative

inefficiencies. Neeraj Sood, Peter J. Huckfeldt, Jose J. Escarce, David C. Grabowski, and Joseph P. Newhouse,

“Medicare’s Bundled Payment Pilot For Acute and Post-acute Care: Analysis and Recommendations on Where to

Begin” Health Affairs, vol. 30, no. 9, (September 2011), pp. 1708-1715.

127

Applicants for Model 1 were to submit a non-binding letter of intent by September 22, 2011 and a completed

application by October 1, 2011. These dates were changed to October 6, 2011 and November 18, 2011 respectively.

Applications for Models 2-4 were originally due by March 15, 2012, but were delayed until June 28, 2012.

128

This will include measuring the spending for included beneficiaries at non-participating providers. According to the

RFA, the risk threshold will be set to account for random variation; the methodology will be provided to awardees prior

to entering their final agreement.

129

Gainsharing is one of MedPAC’s recommended tools to overcome limitations of the current Medicare payment

system in order to increase the value for Medicare beneficiaries and taxpayers. See MedPAC, Report to Congress:

Improving Incentives in the Medicare Program, Washington, DC, June 2009, p. xii, http://www.medpac.gov/

documents/Jun09_EntireReport.pdf. The March 2011 evaluation of Medicare’s gainsharing demonstration programs

can be found here: https://www.cms.gov/reports/downloads/Buczko_Gain_Sharing_Final_Report_May_2011.pdf.

130

CMS has established parameters that must be met by the applicant for an acceptable gainsharing arrangement. See

pp. 23-24 of the RFA http://innovations.cms.gov/documents/pdf/BundledPayments-Request_for_Application_v5.pdf.

(Subsequently referred to as Bundling RFA).

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Table 3 illustrates the differences in eligible services included in the different bundled

payment models.

Table 3. Differences in Eligible Services Included in

the Four Bundled Payment Models

Model 1:

Only Part A

inpatient

hospital care

Model 2: All

inpatient

care (Parts A

& B) plus

post-acute

care

Model 3:

Only postacute care

(Parts A & B)

Model 4:

Only

inpatient

care

Care Related to the Initial Hospitalization

Preadmission Servicesa

X

X

X

Initial Hospitalizationb

X

X

X

X

X

Hospital Physicianc

Care Provided After the Initial Discharge

Post-acute Care (PAC) d

X

X

Related Admissionse

X

X

X

Hospital Physicianc

X

X

X

Community Physicianf

X

X

Other Post-Discharge Servicesg

X

X

Source: CRS adaption of CMS documents and Commonwealth Fund Blog on Bundled Payment Initiative.

a.

Hospital diagnostic testing and all related therapeutic Part A services furnished within 3 days of admission by

an entity wholly owned or operated by the admitting hospital.

b.

Acute care hospital facility Part A services furnished during the hospital stay.

c.

All Part B physician and other professional services provided during the hospital stay.

d.

Related PAC services paid under Parts A and B, including a long-term care hospital, skilled nursing facility,

inpatient rehabilitation facility, and home health agency care.

e.

Part A services for related readmissions and all related Part B services during the post-discharge period

including related and unrelated readmissions.

f.

Physician and other professional services delivered in an outpatient setting including the emergency

department and hospital outpatient department.

g.

Related Parts A or B services including outpatient therapy service clinical laboratory services, durable

medical equipment and Part B drugs.

In Model 1, Medicare will continue to pay acute care hospitals under IPPS, but participating

hospitals will be paid a reduced amount that reflects the applicable discount percentage on all

MS-DRGs. Medicare Part B payments to physicians and other practitioners are not included as

part of the episode and will not change under this model. The hospital is financially responsible if

aggregate Medicare Parts A and B expenditures increase beyond a threshold for the period of the

inpatient stay or during the 30 days after discharge, compared to historical expenditures.

Model 2 spans the widest scope of services, from initial hospitalizations through related

professional services and post-acute care (PAC) as well as care associated with related

readmissions. Model 3 is similar to Model 2, but the episode begins with the first PAC service

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within 30 days of a patient’s discharge from an IPPS hospital for an agreed upon condition. The

IPPS hospitalization is not included in the Model 3 payment bundle. In Models 2 and 3, Medicare

will continue to pay each provider through the traditional claims processing mechanism at the full

FFS rates for the dates of service, but these payments will be retroactively reconciled with the

target price. After an episode of care concludes, the aggregate Medicare expenditures for that

episode of care will be compared to the target price. If the actual expenditures are less than the

target price, Medicare will pay the difference. If the actual expenditures are more than the target

price, the difference will be repaid to Medicare.

In Model 4, Medicare will make a single, prospectively established bundled payment to the acutecare hospital where a beneficiary is hospitalized.131 Unlike the bundled payments under Models 2

and 3, the Model 4 episode does not include PAC services. All Part A services and Part B

physicians’ services furnished during the inpatient stay are included in the bundled payment, and

the hospital will be responsible for distributing the payment to the other providers caring for the

patient. Payment will be based on historical spending trends for all hospital facility and

professional services during the initial hospitalization and related readmissions. The awardee

(whether or not it is the admitting hospital) will be financially responsible for Medicare

expenditures for any related readmissions for at least 30 days. Unlike the Medicare Acute Care

Episode (ACE) demonstration project, none of the program savings will be shared with

beneficiaries.132

A participating provider will receive a bundled payment for all Medicare beneficiaries who

receive care and meet the episode definition. Beneficiaries who meet the eligibility criteria and

receive care from a model participant cannot opt out of the bundled payment program for that

particular provider. These beneficiaries will be notified of the provider’s participation and have

the right to get care from a different provider who is not involved in the bundled payment

initiative. Table 4 summarizes key features of the four bundled payment models in CMMI’s

bundled payment initiative.

131

This model builds on the ongoing Medicare ACE demonstration where bundled payments are made for all Parts A

and B services associated the hospitalization of specified cardiovascular and/or orthopedic procedures in participating

sites. See https://www.cms.gov/DemoProjectsEvalRpts/downloads/ACEFactSheet.pdf.

132

CMS will share up to 50% of the Medicare savings with beneficiaries up to a maximum of the annual standard Part

B premium, (currently $1,199 in 2012) in the ACE demonstration project. (The exact amount of the ACE shared saving

payment to the beneficiary will vary by site and procedure). According to the Request for Applications (RFA), Model 4

will not include sharing savings with patients because past experiences with such policies have proven operationally

challenging to administer and confusing for the beneficiaries. Bundling RFA p. 20.

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Table 4. Characteristics of the Four Bundled Payment Models under CMMI’s

Bundled Payment Initiative

Model 1: Only

Par A inpatient

hospital care

Model 2: All

inpatient(Parts

A & B) plus postacute care

Model 3: Only

post-acute care

(Parts A & B)

Model 4: Only

inpatient care

Eligible

awardees/participating

organizations

Physician group

practices, Inpatient

prospective

payment system

(IPPS) hospitals,

health systems,

physician-hospital

organizations

(PHOs), and

conveners.a

Physician group practices, IPPS hospitals,

health systems, post acute care (PAC)

providers, PHOs, and conveners.

Target conditions

All Medicare

Severity-Diagnostic

Related Groups

(MS-DRGs)

(overlapping MSDRGs covered by

other models will

not be included).

Proposed by applicants. Agreed-upon MS-DRGs for inpatient

hospital stay.

Length of episode

Inpatient stay in the

acute care or IPPS

hospital.

Option 1: 30 to

89 days or

Option 2: a

minimum of 90

days after initial

discharge.

Payment method

Discounted IPPS

payment to hospital.

(physician payments

not included).

Traditional fee-for-service (FFS) payments

to participating entities subject to

reconciliation to predetermined target

price.

At least 30 days

after initial postacute discharge

(which occurs

within 30 days of

discharge from an

acute care hospital

for an included MSDRG).

Physician group

practices, IPPS

hospitals, health

systems, PHOs, and

conveners.

At least 30 days

from discharge.

Prospectively set

bundled payment to

admitting hospital.

Hospital distributes

payments.

See “episode and post-episode reconciliation” row.

Expected Medicare

discount

Minimum discount

of 0.0% in 1st 6

months, 0.5% in 2nd

6 months, 1.0% in

2nd year and 2% in

3rd year. Exact

discount set by

applicant.

Minimum discount

of 3% for episodes

with a postdischarge period of

30-89 days.

Minimum discount

of 2% for 90 day or

longer episodes.

Exact discount set

by applicant.

Episode and postepisode reconciliation

Parts A and B

payments for the

hospital stay that

exceed trended

aggregate payments

beyond a risk

If aggregate FFS payments for included

services during episode exceed a target

amount, entity pays Medicare the

difference. If the reverse occurs, Medicare

pays the difference to the participating

Congressional Research Service

Proposed by

applicant.

Minimum discount

of 3%. A larger

discount would

apply for certain

MS-DRGs (covered

by the ACE

demonstration).

Any Part B

professional claims,

Parts A and B claims

for related readmissions paid

outside the bundled

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Addressing Medicare Hospital Readmissions

Model 1: Only

Par A inpatient

hospital care

threshold will be

repaid.

Parts A and B

payments over a 30

day post-hospital

monitoring period

that exceed a

trended aggregate

payments above a

threshold will be

repaid.

Model 2: All

inpatient(Parts

A & B) plus postacute care

Model 3: Only

post-acute care

(Parts A & B)

organization.

Parts A and B payments over a 30 day

monitoring period that exceed a trended

aggregate payments above a threshold will

be repaid.

Model 4: Only

inpatient care

payment will be

repaid by the

participating

organization.

Parts A and B

payments over a 30

day monitoring

period that exceed

a trended aggregate

payments above a

threshold will be

repaid.

Monitoring period

30 days posthospital discharge.

30 days after the end of the episode.

30 days posthospital discharge.

Quality measures

All Inpatient Quality

Reporting (IQR)

measures and

additional measures

proposed by

applicant.

Proposed by applicants. At some point, CMS will establish a

standardized set of measures that are aligned with other required

measures.

Source: Adapted by CRS from CMS documents.

a.

A convener is an entity such as a state hospital association or a group of providers that can bring together

multiple participating health care providers.

Concluding Observations

Hospitals are required by Medicare’s COP to have a discharge planning process that applies to all

patients. However, the incentives for a hospital to expend significant resources on an effective

discharge planning process within the existing Medicare FFS payment system are blunted.

Medicare is striving to encourage hospitals to adopt care-transition programs and will modify

FFS payment incentives so that hospitals will be more attentive to how this transition care is

provided and the costs of such care. As a positive inducement, CMS is providing technical and

financial assistance to hospitals to enable the adoption of care models so they can better manage

the patient discharge process and address problem areas associated with hospital readmissions.

Future penalties for hospitals with higher than expected readmissions may also motivate change.

Since June, 2009, CMS has included comparisons of hospitals’ 30-day risk-adjusted readmission

rates for aged Medicare patients with AMI, HF, and PN on its Hospital Compare website. Starting

in October, 2012, the importance of the publically reported data will be magnified as lowperforming hospitals will be subject to readmission penalties. The adoption of bundled payment

methods holds the promise of providing clear incentives to avoid service overutilization and

enhance care coordination between providers. Medicare seeks to align financial and other

incentives so that hospitals will proactively identify and track patient problems longitudinally,

rather than treat emergent care crises after they have occurred.

On the other hand, certain issues have been raised about the level of control that hospitals have

over readmissions, particularly since the FFS payment system will still reimburse the majority of

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Addressing Medicare Hospital Readmissions

providers and health care professionals for the volume of services they provide. While some

hospitals will be penalized for having too many readmissions and others will be paid a bundled

payment for certain services, these payment changes are limited in scope and do not correct for

some of the over-riding incentives within the majority of Medicare’s payment systems. Also, as

noted by hospital advocates, readmissions do not depend solely on the quality of inpatient care or

the extent of the care transitions services rendered to a particular beneficiary. Readmissions can

be contingent on the quality and the availability of post-acute and outpatient care, an individual’s

access to such care, an individual’s access to caregivers at home or other unique circumstances. In

the view of CMS, the existing measures adjust for key factors that are clinically relevant and have

strong relationships with patient outcome. The agency seeks to motivate hospitals to work with

their communities to lower readmission rates and improve patient care. These initiatives are

necessary first steps to understand how to address the complicated (and expensive) problem of

Medicare readmissions; CMS has acknowledged the need to monitor its implementation carefully

to prevent untoward impacts on beneficiary access to quality care.

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Appendix A. Hospital Actions That May Mitigate

Against Readmissions

The QIOs, in their 10th Statement of Work’s Care Transitions Theme, and other experts in care

transitions have considered a number of factors that are responsible for hospital readmissions. A

discussion of selected factors is provided in this appendix.

Improving Hospital Discharge Procedures

Hospital discharge planning is intended to provide clear, timely, and understandable information

or instructions to the patient and his or her caregiver or family members, as well as to other

providers outside the hospital setting. This process may include addressing needed post-discharge

services, medications, and equipment, setting up follow-up appointments, coordinating with

families as well as providing some education to patients (and their caregivers) about the transition

to home or other settings, upon discharge. Experts recommend that the discharge process within a

hospital be standardized with an explicit delineation of roles and responsibilities among hospital

staff to ensure that the patient leaves the hospital under the best possible circumstances and

avoids adverse events that could lead to rehospitalization.133 Ideally, the discharge process begins

before the decision that the patient should be discharged is made and education of the patient and

the caregiver should occur throughout the hospitalization, not just at the time of discharge.

Advocates of a standardized discharge process maintain that the discharge summary should be

completed before discharge and updated at time of discharge. A personalized patient health record

may complement the formal hospital discharge summary and should include information

regarding the patient’s medications and dosages, a checklist of items to be completed by the time

of discharge, questions the patient may have for providers outside the hospital setting, among

others. Recently, MedPAC discussions have included adding a COP requirement that hospitals

provide patients’ discharge instructions to the appropriate community provider within 48 hours of

discharge. This COP change has not been proposed by CMS.

Lapses in the hospital discharge planning process can lead to problems with post-discharge care

and with the quality of the patient’s discharge summary. Prior to discharge, a number of different

hospital personnel can provide information to patients about results from laboratory tests,

prescribed medications, and other clinical or therapeutic information as well as instructions about

how to care for a condition and whether post-discharge follow-up care is required. Upon leaving

the hospital, patients may not have a clear idea of what post-acute or community, outpatient care

they require or how best to facilitate their own care.

Generally, fragmented documentation can indicate a problem with hospital discharge planning

and have a significant impact on post-hospital providers’ ability to render competent care. For

example, a patient can be discharged from the hospital before the results of ordered tests have

been completed and included in the discharge summary.134 As recommended by the Society of

133

Also, experts indicate that efficient and safe hospital discharges are significantly more challenging if appropriate

hospital staff are available only during limited daytime hours. Jeffrey L. Greenwald, Charles R. Denham, and Brian W.

Jack, “The Hospital Discharge: A Review of a High Risk Care Transition with Highlights of a Reengineered Discharge

Process,” Journal of Patient Safety, vol. 3, no. 2 (June 2007), pp. 97-106.

134

Up to 41% of general medical patients are discharged from the hospital with pending laboratory tests; as much as

(continued...)

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Hospital Medicine’s Quality and Patient Safety Committee, the checklist in an ideal discharge

summary would include a list of pending tests and the responsible person to whom the results

should be sent.135 One study (of approximately 700 patients in two medical facilities) found large

deficiencies in documenting tests with pending results as well as including information on the

follow-up provider.136 With appropriate documentation of patient information, providers outside

of the hospital setting have access to timely information regarding the patient’s condition, prior

treatment history, medication usage, and laboratory test results, among others.

Improving Patient-Provider Communication

A number of factors may influence the ability of the patient or the caregiver to appropriately

manage the patient’s condition or illness. Ineffective communication between physicians or other

hospital staff and their patients has been identified as a factor leading to lack of prescribed

medication compliance.137 First, a patient may not sufficiently understand his or her condition.

For example, written discharge information may be given to patients with limited literacy or

English proficiency; alternatively, these instructions may conflict with a patient’s cultural values.

Other contributing factors may include cognitive impairment and lack of access to services. The

range and complexity of choices that patients confront—including whether and when to seek

care, how to reconcile conflicting opinions from various providers or family members, and the

introduction of technology into everyday decisions—may make patient engagement

challenging.138

Transitional care teams have emphasized educating patients about warning signs or “red flags”

indicating deterioration in the patient’s health condition.139 Coaching has been used, with the

intent to “activate” patients, in an effort to make them better advocates for their own care, to teach

(...continued)

9.4% of the tests results are abnormal and might change patient care. These pending tests were frequently omitted from

the discharge summaries. Stacy Walz, Maureen Smith, and Elizabeth Cox et al., “Pending Laboratory Tests and the

Hospital Discharge Summary in Patients Discharged to Sub-Acute Care,” Journal of General Internal Medicine, vol.

26, no. 4 (April 2011), pp. 394-398.

135

Lakshmi Halasyamani, Sunil Kripalani, and Eric Coleman et al., “Transition of Care for Hospitalized Elderly

Patients—Development of a Discharge Checklist for Hospitalists,” Journal of Hospital Medicine, vol. 1, no. 6

(November/December 2006), pp. 354-360.

136

Only a quarter of the discharge summaries mentioned any pending tests. Only 13% of the summaries mentioned all

pending tests. Follow-up provider information was documented in less than 70% of the summaries. Martin C. Were,

Xiaochun Li, and Joe Kesterson et al., “Adequacy of Hospital Discharge Summaries in Documenting Tests with

Pending Rusults and Outpatient Follow-up Providers,” Journal of General Internal Medicine, vol. 24, no. 9 (July

2009), pp. 1002-1006.

137

Edward C. Rosenow III, “Patients’ Understanding of and Compliance With Medications: The Sixth Vital Sign?”

Mayo Clinic Proceedings, vol. 80, no. 8 (August 2005), pp. 983-987.

138

Carolyn M. Clancy, “Patient Engagement in Health Care," Health Services Research, vol. 46, no. 2 (April 2011), pp.

389-393.

139

As noted in the section of the report on CTTP for High Risk Beneficiaries, several of the care transition programs

specifically address “red flags” or warning signs that a patient’s condition is worsening and steps to take in those cases.

For instance, see Eric A. Coleman, Carla Parry, Sandra Chalmers, and Sung-Joon Min, “The Care Transitions

Intervention: Results of a Randomized Controlled Trial,” Archives of Internal Medicine, 2006;166(17): pp. 1822-8. In

the Care Transitions Initiative (CTI), a transition “coach” educates a patient about red flags related to the patient’s

condition and specific red flags during the hospitalization (symptoms and drug reactions); during a post-discharge

home visit (symptoms and adverse effects of medications); as well as during post-discharge telephone calls

(instructions regarding when to call a primary care provider).

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Addressing Medicare Hospital Readmissions

patients and their caregivers the steps to take in the event of an emergency, and to improve

patients’ ability to communicate with other providers they encounter. “Activation” itself—an

emerging topic of study in health services research—has been associated with better quality of

care.140 However, adequate patient follow-up can also be also dependent on the availability of

patient resources, such as housing and the presence of informal caregivers, factors that are outside

the control of the hospital.141

In addition, studies suggest that post-discharge contact with patients by hospital personnel or

transitional care staff can address patient-provider communication gaps and patient compliance

issues. There has been mixed evidence from the substantial amount of research evaluating the

benefit of post-discharge telephone calls, either as one part of a transitional care program or as a

separate intervention.142 However, certain proponents support the implementation of a postdischarge phone call program to reinforce discharge instructions, medication changes and followup care plans as well as to monitor clinical developments of these patients and to intervene if

necessary. Given the resources necessary for the program, targeting high risk patients may be

warranted.143

Targeting Patients at Risk of Readmission

Generally, determining which readmissions are appropriate or which readmissions may be

preventable involves a complex set of questions that are subject to intense debate among hospital

advocates, researchers and policy makers. Academics have developed predictive models to

identify which patient populations are at greatest risk for hospitalizations and

rehospitalizations.144 However, these clinical models used to predict readmission risk have limited

success with such predictions.145 Alternatively, hospitals can identify patients who have a high

risk of readmissions and are appropriate candidates for intervention, such as those with a history

140

Richard. L. Skolasky, Ariel Frank Green, Daniel Scharfstein, Chad Boult, Lisa Reider, and Stephen T. Wegener,

“Psychometric Properties of the Patient Activation Measure Among Multimorbid Older Adults," Health Services

Research,vol. 46, no. 2 (April 2011).

141

Gheorghiade et al., “Improving Post Discharge Outcomes’ JAMA no. 305, vol. 23, pp. 2456-2457.

142

Most of the studies evaluating the effectiveness of post-discharge calls as an independent intervention have low

patient numbers and high risk of bias. Many of the interventions focus on certain diagnoses or localized groups of

patients. Also, the primary and secondary outcomes have varied across the studies and have included patient

satisfaction, reduction in medication errors, and effect on readmissions or repeat emergency department visits. Spotlight

Case: Postdischarge Follow-up Phone Call. WebM&M, March 2012, Agency for Healthcare Research and Quality

143

Published research indicates that most post-discharge phone calls take 10 to 20 minutes. However, depending upon

the patient’s situation, pharmacists, physicians, and case managers may become involved to identify and address issues

and then provide information to the patient’s community providers. Ibid.

144

Joseph Ross, M.D., M.H.S.; Gregory Mulvey, Brett Stauffer, Vishnu Patlolla, Susannah Bernhein, Patricia Keenen,

Harlan Krumholz, “Statistical Models and Patient Predictors of Readmission for Heart Failure: A Systematic Review,”

Archives of Internal Medicine, vol. 168, no. 13, (July 14, 2008), pp. 1371-1385. There are key differences between

models that seek to predict patient risk of readmission from those that profile and compare hospital readmission rates.

Among other differences, most patient risk models rely on clinical information and laboratory test results while

profiling models use more easily accessible administrative data, such as billing information that is submitted on claims.

As noted by the authors, most patient risk models accounted for patient characteristics (such as length of stay, discharge

disposition, in-hospital events and complications, and patient income education, and race/ ethnicity) that may be

inappropriate to include in profiling models . Accounting for such characteristics could inappropriately risk-standardize

hospital performance for the differences in quality and efficiency that profiling efforts attempt to measure.

145

Devan Kansagara, Honora Englander, and Amanda Salanitro et al., “Risk Prediction Models for Hospital

Readmission: A Systematic Review,” JAMA, vol. 306, no. 15 (October 19, 2011), pp. 1688-1698.

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of a recent admission or readmission, those with longer-than-expected stays or high-risk

diagnoses and those with diabetes.

As currently structured, the HRRP program provides some incentive for hospitals to focus on

managing the readmissions for Medicare patients initially admitted with one of the three

applicable conditions, (at least until additional measures can be adopted in FY2015).

Alternatively, hospitals may see attempts to target efforts to select patient populations as more

costly than implementing systemic procedural and programmatic changes to address

readmissions, particularly if the HRRP program is seen as likely to expand to other conditions or

if other insurers are apt to become concerned with readmissions. As noted previously in Table 2,

transitional care interventions frequently target patients with certain characteristics and individual

circumstances, so hospitals could focus on managing the readmissions of the patients best situated

to stay out of the hospital for 30 days. Simply, the response of any given hospital is difficult to

predict in the abstract.

Accessing and Training Available Caregivers

Caregivers—family and friends who provide care generally without compensation—can play a

significant role in th

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